Suspicious Activity Monitoring and Reporting. Within 60 days of the Agreement, the Bank shall submit an enhanced written program acceptable to the Reserve Bank to reasonably ensure the identification and timely, accurate, and complete reporting by the Bank of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. At a minimum, the enhanced program shall include:
Suspicious Activity Monitoring and Reporting. (a) Correspondent shall be responsible for monitoring customer accounts for any suspicious transactions. In this regard, Correspondent will monitor, on a regular basis, among other things, customer activity introduced by Correspondent for clearing, including but not limited to trading, wire transfers into accounts maintained on behalf of customers, Journals and the deposit of and withdrawal from customer accounts of funds or other assets.
(b) Correspondent shall immediately notify Apex of any suspicious transactions it detects or of which it is aware with respect to the accounts of customers for whom it introduces transactions to Apex. Correspondent shall be responsible for filing with the Department of Treasury any resulting Suspicious Activity Reports as required by the Patriot Act.
(c) Apex may file with the Department of Treasury Suspicious Activity Reports related to suspicious transactions in Correspondent accounts detected by Apex.
(d) Apex may file with the Internal Revenue Service, and any other applicable regulatory bodies, joint FinCEN/IRS forms, as required by applicable law, with respect to transactions in which it receives more than $10,000 in currency or coins. Such reports will be filed pursuant to the relevant procedures set forth in Apex’s anti- money laundering compliance program.
(e) Correspondent shall maintain for at least 6 years (or such longer period as is required under any applicable laws, rules and/or regulations) all necessary records and background documentation on such filings to enable Correspondent to comply with any request for information from Apex.
Suspicious Activity Monitoring and Reporting. (1) Within one hundred twenty (120) days of this Agreement, the GM shall ensure that the Branch develops, implements, and thereafter adheres to an enhanced written risk-based program of internal controls and processes to ensure, pursuant to 12 C.F.R. § 21.11, the timely and appropriate review and disposition of BSA/AML suspicious activity alerts and the timely filing of Suspicious Activity Reports (“SARs”). This written Branch program shall include, at a minimum:
(a) Procedures for identifying, monitoring and reporting suspicious activity, known or suspected violations of Federal law, violations of the BSA, or suspicious transactions related to potential money laundering across all Branch lines of business, including suspicious activity relating to the opening of new accounts, the monitoring of existing accounts, and the transfer of funds through the Branch, consistent with the Suspicious Activity Reporting section of the FFIEC BSA/AML Examination Manual;
(b) Application of appropriate thresholds and filters for automated surveillance systems in monitoring all types of transactions, accounts, customers, products, services, and geographic areas that include, at a minimum:
(i) Meaningful thresholds and alert scenarios for filtering accounts and customers for further monitoring, review and analyses;
(ii) Adequate documentation supporting the Branch’s methodology for establishing alert thresholds and filters; and
(iii) Periodic independent validation of thresholds and filters for their appropriateness to the Branch’s customer base, products, services, and geographic area;
(c) Appropriate linkage between EDD information and suspicious activity monitoring functions to ensure BSA/AML staff appropriately use EDD information in suspicious activity investigations;
(d) Procedures to address cases where there is on-going suspicious activity to ensure appropriate management review and determination of whether the customer relationship should be continued;
(e) Meaningful, accurate, and timely reporting to the HO, or designated committee, and management of suspicious activity investigations and SAR filings;
(f) Review of any new surveillance systems to ensure it has the capacity to operate on multiple platforms and is appropriate for the Branch’s size and complexity;
(g) Procedures to ensure the Branch files SARs within the time frames specified in the applicable rules, regulations, and regulatory guidance, and files follow-up SARs every ninety (90) days in cases where s...
Suspicious Activity Monitoring and Reporting. Within 60 days of the Agreement, SSC and the Bank shall jointly submit a written revised program acceptable to the Supervisors to reasonably ensure the identification and timely, accurate, and complete reporting by SSC, its nonbank subsidiaries, and the Bank, as applicable, of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. At a minimum, the revised program shall include:
Suspicious Activity Monitoring and Reporting. Within 90 days of this Agreement, DFS shall submit a written program acceptable to the Reserve Bank to reasonably ensure the identification and timely, accurate, and complete reporting of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities for transactions at, by, or through DFS or its nonbank subsidiaries, as required by section 225.4(f) of Regulation Y of the Board of Governors (12 C.F.R. § 225.4(f)). At a minimum, the program shall include:
Suspicious Activity Monitoring and Reporting. Banks are required to report suspicious activity that may involve money laundering, BSA violations, terrorist financing, and certain other crimes above prescribed dollar thresholds. Any customer or transaction that fails any stage of Prosper’s verification procedures or that exhibits other risk factors is manually reviewed by Pxxxxxx’s Risk team. As a part of this process, if Pxxxxxx knows, suspects, or has reason to suspect, (1) insider abuse (in any amount), or (2) any suspicious transaction involving a violation of federal law of $5,000 or more, Pxxxxxx will aid WebBank in filing its Suspicious Activity Report (“SAR”) by providing sufficient information for WebBank to complete its Treasury Form TD F 90-22.47. Prosper will develop and maintain sufficient operational procedures to allow its employees to identify red flags for suspicious activity, including when transactions are: · Obtained from illegal activity · Intended or conducted to hide or disguise funds or assets derived from illegal activity · Designed to evade any reporting requirements of the Bank Secrecy Act (BSA) · Transacted with no business or lawful purpose · Not the sort the customer normally engages · Pxxxxxx knows of no reasonable explanation for the transaction after examining available facts including the background and possible purpose of the transaction Bank Secrecy Act Policy Pxxxxxx, its directors, officers, employees, and agents will not notify any person involved in the suspicious transaction that information has been provided to WebBank for purposes of filing a SAR, or that a SAR has been reported. Prosper shall retain the information provided to WebBank for the purposes of filing SARs and any supporting documentation for five (5) years from the date the information was reported.
Suspicious Activity Monitoring and Reporting. Within 60 days of the submission of the Compliance Report, the Bank and the Branch shall jointly submit to the Supervisors an acceptable written program to reasonably ensure the identification and timely, accurate, and complete reporting by the Branch of all known or suspected violations of law or suspicious transactions to law enforcement and supervisory authorities, as required by applicable suspicious activity reporting laws and regulations. At a minimum, the program shall include:
