Financial institutions may become aware of unusual or suspicious activity from a variety of sources, including manual transaction monitoring, automated Anti-Money Laundering (AML) software systems, law enforcement inquiries, and requests such as 314a requests, subpoenas, national security letters, or employee notifications. Once such activity has been identified, the incident or alert must be reviewed and investigated.
Some alerts require limited investigation and documentation, while others require expanded investigations and detailed documentation of the results. Alerting management is not a one-size-fits-all process, but enough information must be gathered, analyzed, and documented to make a determination whether a Suspicious Activity Report (SAR) should be filed or whether a “no SAR” file is necessary.
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