Suspicious Activity Reporting. You must immediately notify us if you detect any money laundering red flags, so that CSB can determine whether a suspicious activity report (SAR) must be filed with the U.S. Department of the Treasury. Typically a SAR must be filed within thirty (30) days of the initial detection of the suspicious activity. Insurance Industry red flags include but are not limited to: • The purchase of a product that appears to be inconsistent with a customer’s needs; • The purchase or funding of a product that appears to exceed a customer’s known income or liquid net worth; • Any attempted unusual method of payment, particularly by currency or cash equivalents such as money orders, traveler’s checks or cashier checks; • Payment of a large amount broken into small amounts; • Little or no concern expressed by a customer for the investment performance of an insurance product, but much concern expressed about the early termination features of the product; • The reluctance of a customer to provide identifying information, or the provision of information that seems fictitious; • A customer’s inquiring about how to borrow the maximum amount available soon after purchasing the product; • Listing a beneficiary or payee who is apparently an unrelated third party or who otherwise has no apparent relationship to the customer; • A customer applies for a policy out of state when the same or similar product is available in his/her home state; • The customer uses an out of state mailing address; and • Any other activity that you think is suspicious. If you identify any suspicious activity or money laundering red flags, you must promptly notify the CSB AML Compliance Contact, Xxxxxxxxx Xxxxxx, at 000-000-0000. In that regard, you may be asked by the CSB AML Compliance Contact or by other CSB management personnel to investigate further or obtain additional information from the customer. If so requested you must expeditiously obtain any requested information so CSB can determine in a timely manner if a SAR needs to be filed.
Suspicious Activity Reporting. FMER agrees that on behalf of SunTrust, it will monitor for any potential or actual suspicious activity detected regarding any Services that FMER performs on behalf of SunTrust, including any potential or actual suspicious activity which is committed by Applicants or Borrowers. Such suspicious activity includes any potential or actual activity or transaction that would require SunTrust to file a Suspicious Activity Report as described in the USA PATRIOT Act or 12 C.F.R. § 208.62 (“USA PATRIOT Act”) or other activity which involves fraud, violations of federal, state or local law or which appears to have no legitimate purpose. If FMER becomes aware of any potential or actual suspicious activity, FMER will promptly, and in all cases within seventy-two (72) hours, notify SunTrust’s Consumer Lending Operations Department of the precise nature of any such activity and provide SunTrust with any information and documents concerning the matter. Further, FMER agrees to reasonably cooperate with SunTrust and to provide SunTrust with any additional information and documentation requested regarding any investigation of potential or actual suspicious activity. The contact in the SunTrust’s Consumer Lending Operations Department is Xx. Xxxxx Xxxxxxxxx, whose contact information is: Telephone: (000) 000-0000, Fax: (000) 000-0000, E-Mail: xxxxx.xxxxxxxxx@xxxxxxxx.xxx. SunTrust may change its contact in its Consumer Lending Operations Department at any time by written notice to FMC and FMER that meets the requirements of Section 19.1.
Suspicious Activity Reporting. We are required by Applicable Law to report suspicious activities relating to money laundering, bribery or corruption to the relevant money laundering reporting officers, regulators and/or other authorities in which event we would be prohibited by Applicable Law from notifying anyone that a report has been made. In certain circumstances, We may be required to suspend the Services or terminate Our relationship with You without giving You Our reason(s).
Suspicious Activity Reporting. FMER agrees that on behalf of Lender, it will monitor for any suspicious activity detected regarding any Services that FMER performs on behalf of Lender. Such suspicious activity includes any transaction that would require Lender to file a Suspicious Activity Report as described in the USA PATRIOT Act or 12 C.F.R. § 208.62 (“USA PATRIOT Act”) or other activity which involves fraud, violations of federal, state or local law or which appears to have no legitimate purpose. If FMER becomes aware of any such suspicious activity, FMER will promptly, and in all cases within ten (10) Business Days, notify Lender of the nature of any such activity and provide Lender with information and documents concerning the matter. Further, FMER agrees to reasonably cooperate with Lender and to provide Lender with any additional information and documentation requested regarding any investigation of suspicious activity.
Suspicious Activity Reporting. FMER agrees that on behalf of SunTrust, it will monitor for any potential or actual suspicious activity detected regarding any Services that FMER performs on behalf of SunTrust, including any potential or actual suspicious activity which is committed by the Primary Applicant or Secondary Applicant, as applicable, or the Borrower or the Cosigner. Such suspicious activity includes any potential or actual activity or transaction that would require SunTrust to file a Suspicious Activity Report as described in the USA PATRIOT Act or 12 C.F.R. § 208.62 (“USA PATRIOT Act”) or other activity which involves fraud, violations of federal, state or local law or which appears to have no legitimate purpose. If FMER becomes aware of any potential or actual suspicious activity, FMER will promptly, and in all cases within seventy-two (72) hours, notify SunTrust’s Consumer Lending Operations Department of the precise nature of any such activity and provide SunTrust with any information and documents concerning the matter. Further, FMER agrees to reasonably cooperate with SunTrust and to provide SunTrust with any additional information and documentation requested regarding any investigation of potential or actual suspicious activity. The contact in the SunTrust’s Consumer Lending Operations Department is Xx. Xxxxx Xxxxxxxxx, whose contact information is: Telephone: (000) 000-0000, Fax: (000) 000-0000, E-Mail: xxxxx.xxxxxxxxx@xxxxxxxx.xxx. SunTrust may change its contact in its Consumer Lending Operations Department at any time by written notice to FMC and FMER that meets the requirements of Section 19.1.
Suspicious Activity Reporting. (1) Within ninety (90) days, the Board shall develop, implement, and thereafter ensure Bank adherence to a written program of policies and procedures to ensure compliance with the requirements of 12 C.F.R. Part 21, Subpart B. At a minimum, this written program shall establish procedures for identifying and reporting known or suspected violations of Federal law, violations of the Bank Secrecy Act, or suspicious transactions related to money laundering activity, including suspicious activity relating to the opening of new accounts, the monitoring of current accounts, and the transfer of funds through the Bank as well as:
(a) a process for identifying high-risk customers;
(b) revising the bank’s Customer Information Program (CIP) to ensure that the CIP is more risk-based;
(c) adequate controls and procedures to ensure that all customers with Money Service Businesses (MSB) are properly identified and monitored; and
(d) policies and procedures to identify potential Politically Exposed Persons (PEP) and foreign political figures to identify and monitor the activity of any such individuals who may utilize bank services. ensure that records are maintained on monetary instrument transactions and funds transfers, as required by the Bank Secrecy Act;
(e) a comprehensive training program for all appropriate operational and supervisory personnel to ensure their awareness of and compliance with the requirements of the Bank Secrecy Act and the Office of Foreign Assets Control (OFAC), including the currency reporting and monetary instrument and funds transfer recordkeeping requirements, and the reporting requirements associated with Suspicious Activity Reports (SARs) pursuant to 12 C.F.R. Part 21, Subpart B.
(2) Upon completion, a copy of this program shall be submitted to the Assistant Deputy Comptroller for review. In the event the Assistant Deputy Comptroller recommends changes to the program, the Board shall immediately incorporate those changes into the program.
(3) The Board shall ensure that the Bank has processes, personnel, and control systems to ensure implementation of and adherence to the program developed pursuant to this Article.
