Suspicious Activity Monitoring and Reporting Program. 4. Within 60 days of this Agreement, the Bank and the Branch shall jointly submit a written program reasonably designed to 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, acceptable to the Reserve Bank. At a minimum, the program shall include:
Suspicious Activity Monitoring and Reporting Program. (1) Within ninety (90) days of the date of this Agreement, the Board shall ensure Bank management develops, implements, and adheres to an enhanced written risk-based program, pursuant to 12 C.F.R. § 21.11, to ensure the timely identification, analysis, and suspicious activity monitoring and reporting for all lines of business, including activities provided by and through the Bank’s third-party fintech relationship accounts and sub-accounts (“Suspicious Activity Monitoring and Reporting Program”).
Suspicious Activity Monitoring and Reporting Program. 4. Within 60 days of the effective date of this Agreement, the Bank shall submit a written revised program acceptable to the Supervisors reasonably designed to 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. The program shall include procedures to ensure the timely detection, investigation, and reporting of all known or suspected violations of law and suspicious transactions, including the following three items:
