Martha Whitmire, the BSA Compliance Officer for First National Bank, is responsible for monitoring the bank's daily currency activity and wire transfers, for compliance with information retention and reporting requirements. Ms. Whitmire notices during her review on March 10 that, during the previous two weeks, a transaction occurred on the same account several times during the week. The activity appeared at one branch office as cash deposits in dollar amounts under the reporting thresholds. Ms. Whitmire discusses this activity with the branch manager and determines that this same deposit activity occurred several times during the previous six weeks. She then conducts a more extensive examination of the account's activity for several months and discovers that cash deposits were made at one branch office and purchases of bank cashiers checks were made by withdrawals from the same account at a different branch office. All withdrawals and purchases of cashier's checks were for the identical amount as the cash deposits. Which statement best describes Ms. Whitmire's responsibility?

Question

Quizplus · Accepted Answer

Ms. Whitmire's examination of the account's activity suggests a pattern of structuring that meets the regulatory definition of suspicious activity. A SAR (Suspicious Activity Report) should be filed and proper due diligence should be undertaken to establish the legitimacy of the activity. Choice A is incorrect because a CTR (Currency Transaction Report) is required only for transactions exceeding the reporting thresholds, not for structuring. Choice B is incorrect because a late discovery does not exempt the bank from filing a SAR once unlawful activity has been identified. Choice C is incorrect because the line of authority and decision-making for filing a SAR should be more independent of senior management.