bank secrecy act / anti-money laundering (bsa/aml) compliance

INTERNAL CONTROLS - REPORTINGSUSPICIOUS ACTIVITY REPORTS Policies, procedures and processes should includeprocedures for: Designating the person responsible for the identification,research and reporting of suspicious activities; The monitoring and identification of unusual activity; The referral of unusual activity to the appropriate person ordepartment responsible for evaluating unusual activity; Documenting the decision whether to file a SAR; Considering closing accounts as a result of continuoussuspicious activity;INTERNAL CONTROLS - REPORTINGSUSPICIOUS ACTIVITY REPORTS Completing, filing and retaining SARs and their supportingdocumentation; Reviewing and evaluating the transaction activity of subjectsincluded in law enforcement requests; and Subpoenas, section 314(a) requests and NationalSecurity Letters (NSLs). Reporting SARs to the board of directors, or a committeethereof, and senior management.20