I helped present a webcast yesterday. Here's a tip from a viewer that is worth sharing.
"I wanted to make a suggestion to credit unions regarding OFAC scans and was thinking maybe you could help share it. So many CUs ask about how often they should scan their members, or even their vendor lists. My suggestion to everyone is to scan your membership (and other lists) when the lists change, not necessarily on a specific, periodic basis. For example, yesterday the terrorists lists were updated. This morning, I scanned our membership and vendor lists after ensuring our scanning software had been updated. Obviously transactions need scanned much more promptly."
That seems to be a sound, risk-based procedure.
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Also, I made a whoopsy-daisy during yesterday's webcast. The time line for filing a SAR is as follows:
"The SAR rules require that a SAR be filed no later than 30 calendar days from the date of the initial detection of facts that may constitute a basis for filing a SAR. If no suspect can be identified, the time period for filing a SAR is extended to 60 days." 2007 FFIEC BSA/AML Examination Manual.
Apologies for the slip-up!
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