Should Involvement of Third Party Debt Consultants Trigger SAR Requirements?

The following is an article reprinted with permission from the upcoming Fall 2010 edition of The WWR Letter: Should Involvement of Third Party Debt Consultants Trigger SAR Requirements? By: Robert Rutkowski, Partner In April of 2009, and again in June of 2010, the Financial Crimes Enforcement Network (“FinCEN”) issued advisories on foreclosure rescue scams. Particularly…

Rob’s Summer/Fall Speaking Schedule

Summer and fall are shaping up to be a very busy seminar season for Rob! Below is a list of venues where he will be presenting through the end of the year as well as information on how to sign up to attend these seminars. July 16, 2008: Rob will be teaming up with CU…

Structuring

Structuring is “the breaking up of transactions for the purpose of evading the Bank Secrecy Act reporting and recordkeeping requirements.”  See FinCen Ruling 2005-6 – Suspicious Activity Reporting (Structuring).    A member might try to deposit funds over a period of days or go to multiple branches of the credit union to try to hide the…