Pub. 15 2020-2021 Issue 4

WWW.NEBANKERS.ORG 20 Steve Manderscheid brings over 25 years of financial industry experience to the Compliance Alliance team. Previously, he focused on all aspects of regulatory compliance risk management while also serving in a Bank Secrecy Act officer capacity. In recent years, he has ventured into leadership roles in enterprise-wide risk management (ERM), complaint management, and vendor and third-party relationships. In his role as Compliance Officer, Steve brings all of his experience to completing reviews, and working on developing tools, training materials, and training events for our members. Recently, he's started expanding his educational role and has become the main presenter of our popular C/A Minute videos. Remember, the battle against suspicious activity has only begun at the identification stage. Once identified, the bank still has the responsibility to review and research the activity and ultimately come to a final SAR decision. If a decision is made to file a SAR related to the COVID-19 pandemic, it is important to provide information with a high degree of usefulness for government authorities, including law enforcement. FinCEN has requested that appropriate information is included in any report to help identify the fraud, such as: • If the suspicious activity is related to an ACH payment from a state unemployment insurance program, please clearly mention COVID19 UNEMPLOYMENT INSURANCE FRAUD in field 2 of the SAR (Filing Institution Note to FinCEN) as well as in the narra - tive. This will make it much easier for your SAR to get to law enforcement teams working with the states on unemployment fraud. • Or if the activity involves a counterfeit check or ACH payment for the EIDL program, please also clearly mention COVID19 EIDL FUNDS FRAUD in field 2 of the SAR (Filing Institution Note to FinCEN) and state this in the narrative, as there are specific prosecutorial teams working on EIDL fraud. Remember, financial institutions should provide all pertinent available information in the SAR and narrative. The better the story (i.e., the narrative), the more likely it will assist law en - forcement to identify and act against COVID-19-related crimes. 8 0 0 - 3 7 3 - 3 0 0 0 | f i n s a l e s @ d b e i n c . c o m NCR GLOBAL CUSTOMER ENGAGEMENT Pa r t ne r o f t he Yea r At DBE , we v a l ue t he r e l a t i on s h i p s t ha t a r e bu i l t by do i ng t he r i gh t t h i ng f o r ou r c u s t ome r s . I n r e cogn i t i on o f t he pa r t ne r s h i p s we have f o rmed ove r t he ye a r s , we a r e hono r ed t o be named t he G l oba l Cu s t ome r Engagemen t Pa r t ne r o f t he Yea r f r om NCR . Th i s awa r d i s g r an t ed t o one o f t he 550 g l oba l pa r t ne r s o f NCR w i t h t he h i ghe s t Ne t P r omo t e r s co r e s when s u r veyed by NCR . We a r e t r u l y hono r ed t o r e c e i ve t h i s awa r d and wan t t o s ay a s pe c i a l t hank you t o t he c u s t ome r s who con t i nue t o c hoo s e DBE a s t he i r t e c hno l ogy pa r t ne r. A l s o , a s pe c i a l t hank you t o ou r v a l ued t e amma t e s who do e ve r y t h i ng i n t he i r powe r t o pu t t he c u s t ome r i n t he c en t e r o f a l l t ha t we do . As we continue to do our part to fulfill our BSA regulatory duties, it is important to remember those that may be impacted most – customers and community members. Continue the good fight and remain vigilant during these challenging times and help protect those most susceptible to being taken advantage of from those bad actors.  Automated account monitoring systems can certainly make it easier to identify individual transactions, patterns of unusual activity, or deviations from expected activity. Compliance Alliance — continued from page 19