Suspicious Activity Reporting

Suspicious Activity Reporting. All employees are required to be vigilant for indicators of suspicious activity and to promptly report any such activity to the BSA/AML Compliance Officer or through the institution's designated reporting channels. The BSA/AML Compliance Officer shall evaluate all reports of suspicious activity and, where warranted, shall file a Suspicious Activity Report (SAR) with the Financial Crimes Enforcement Network (FinCEN) within thirty (30) calendar days of the initial detection of facts that may constitute a basis for filing. If no suspect has been identified, the filing deadline may be extended to sixty (60) days. A SAR shall be filed for any transaction or pattern of transactions that involves or aggregates at least $5,000 in funds or other assets and the institution knows, suspects, or has reason to suspect that: (a) the transaction involves funds derived from illegal activity; (b) the transaction is designed to evade BSA reporting requirements; (c) the transaction has no business or apparent lawful purpose; or (d) the transaction involves the use of the institution to facilitate criminal activity. SAR filings are confidential and shall not be disclosed to any person involved in the reported transaction.