CAMS · Question #78
A bank compliance officer discovers cash deposit activity inconsistent with the expected and historical cash activity within the personal accounts of the chairman of the board. The cash activity…
The correct answer is B. Follow the financial institution's established STR reporting policy. The best option for the compliance officer is to follow the financial institution's established STR reporting policy, which should include procedures for reporting suspicious activity involving senior management or board members. This would ensure that the compliance officer…
Question
A bank compliance officer discovers cash deposit activity inconsistent with the expected and historical cash activity within the personal accounts of the chairman of the board. The cash activity appears structured to avoid the local legal filing requirements for large cash transactions, and a suspicious transaction report (STR) was filed. How should the compliance officer report the filing of the STR to the board of directors without revealing the existence of the filing to the subject?
Options
- AInform the legal counsel of the bank
- BFollow the financial institution's established STR reporting policy
- CNotify the financial institution's regulator to disclose the activity
- DThe compliance officer and the chief executive officer should jointly interview the chairman
How the community answered
(26 responses)- A12% (3)
- B77% (20)
- C8% (2)
- D4% (1)
Explanation
The best option for the compliance officer is to follow the financial institution's established STR reporting policy, which should include procedures for reporting suspicious activity involving senior management or board members. This would ensure that the compliance officer acts in accordance with the bank's internal controls and governance, and avoids any potential conflicts of interest or breaches of confidentiality. The other options are not advisable because they could either compromise the integrity of the STR filing, expose the compliance officer to legal or reputational risks, or alert the subject of the investigation.
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