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One of our employees embezzled money from the bank. We fired the employee and filed a SAR, but we did not contact local law enforcement or prosecute the crime. Do we have any duty to make any other reports about the crime? – IBA Compliance Connection

IBA Compliance Connection

Your go to source for compliance!

One of our employees embezzled money from the bank. We fired the employee and filed a SAR, but we did not contact local law enforcement or prosecute the crime. Do we have any duty to make any other reports about the crime?

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We recommend contacting your primary regulators so that they are aware of what happened. You also should check any insurance or bonding agreements, which may require your institution to report the crime to your insurance company. We found this BankNews article about employee embezzlement helpful, as it recommends the same steps after discovering bank employee fraud (filing a SAR, notifying your insurance company, and keeping your regulators informed).