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Investigations, Reporting

Many of our customer’s debit cards were compromised during that Target fiasco. Our bank’s Vice President feels that a SAR should be filed stating the amount of cards that were affected. Are there any filing requirements per regulations that would require me to file the SAR in this situation?

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Policies & Procedures

Currently we scan our customer base against the entire SDN list (for example) upon an update notification. However, I want to be able to scan ONLY against the changes to the list. I have been trying to find, unsuccessfully, if OFAC provides a file that contains only the updated information – does anyone know if this exists and where it is located?

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Financial Crime Methods

Recently I heard from a colleague that a foreign bank in Europe had accepted a fraudulent wire. The issue I am trying to get some feedback on is the following: the wire instructions provided by the hacker/fraud included the name of the client and the bank routing and account number of an account at the foreign bank with a different name. In my experience here in the United States the receiving bank will generally kick the wire back because the name on the receiving account does not match the wire instructions. Is this type of policy a global one?

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Diligence

We are currently Risk Rating our customers on a 1-3 scale and are considering changing this model to allow for varying levels of risk based on multiple factors outside of those determined at account opening, type of customer, etc. Typically we risk rate our NRA customers as Moderate Risk but the norm is that they tend to be low risk. Is anyone willing to share their risk rating process and approach?

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Government

Can anyone explain to me (or better yet, point me in the right direction to find articles on) the AML and Anti-Corruption policies and practices of Hong Kong and China?

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