An Unusual Activity Referral (UAR), completed in Verafin, is required when handling a transaction that appears suspicious. If you handle a transaction that you feel is suspicious, discuss it with your supervisor. Submit completed UAR's to the Bank Secrecy Act (BSA) Department for review and further investigation. BSA requests for additional information regarding the client or the suspicious transaction should be handled promptly.

Federal regulations require timely reporting of any activity that is unusual or suspicious for a particular client. Capital City Bank BSA Department creates and submits a Suspicious Activity Report (SAR) from the information contained in the UAR submitted by the associate.

A UAR is confidential and information regarding the UAR is disclosed only to other associates on a "need to know" basis. It is a federal crime to tell a client that a SAR has been filed in connection with a transaction and sharing such information is a basis for automatic termination.

The following are examples of transactions that require a UAR:

To create and submit a UAR, do the following:

1. Sign in to Verafin.
   • If the Verafin system is down, see the Disaster Recovery tab.
   • New Users:
     • Username - CCB email address
     • Temporary password - Password20+
     • For password resets of disabled users contact the Help Desk at ext. 397400.
2. In the menu bar on the left, click the Teller icon.  
    
3. In the Teller Home screen, click Unusual Activity Referral.
   
4. Click Search customers.
   
5. Enter Client Name.
6. Click Select.
   
7. In the Referral Type field, use the drop-down menu to choose BSA/AML. 
   
8. In the Referral Details section, enter as much information as possible regarding suspicious activity or fraud. At a minimum, the following information is required:
   • Who
   • What
   • Where
   • When
   • How
9.  In the Attachments field, drag & drop or upload files to attach to the UAR.
10. Click Submit once all sections have been completed.

The Transactional Risk & Fraud Prevention (TR&FP) department or retail designee will submit an Unusual Activity Referral (UAR) to the BSA Department utilizing Verafin in any instance involving completed or attempted fraud over $5,000 whether or not a loss to the bank was identified, or for any amount if the fraudulent activity involved an insider. If no loss was identified for the client/bank the UAR would be completed upon account closure.

Examples of referral reasons include:

• Charged back transactions with or without a loss to the bank
• Check casher
• Any type of account fraud
• Altered/fictitious checks
• Fraud activity of any amount involving insiders
• NSF attempted with chargeback should be given consideration for suspicion of intent to defraud
• Anything of $5,000 in completed or attempted activity

To complete and submit a Fraud UAR in Verafin, do the following:

1. Complete the Unusual Activity Referral - Fraud - Template form. 

   • Sample - UAR Fraud Form

     Unusual Activity Referral - Fraud
     Referrer Name: Name of the person completing the form.   Office Location: Office location of the referrer.   Referral Date: Click here to enter a date.          Click to select the date of the referral.
     Client information
     Client Name & CIF: Client name and their CIF should be noted in this section. Example: Client Name A123456
     Account(s) Involved in the fraudulent activity: Any account affected by the fraudulent activity whether completed or attempted. Example: 10000123456 & 40000123456
     Total amount of fraudulent activity: $6,000 (total amount of completed or attempted activity)	Loss to bank: $6,000 (include any known loss to the bank)
     Type of fraud taking place: Note the type of fraud being reported, i.e. new account fraud, check fraud, wire fraud, ACH fraud, etc.
     Action taken on account: If any action was taken note it here, otherwise type N/A. *There may be more than one option listed in this section.  Examples: account closed, debit card warmed, hold placed on funds, new account opened, client added to positive pay, client added to ACH fraud control.
     Is the client a victim?  Yes ☐     No ☐ - Has the client acknowledged their involvement in the activity?   Did the client complete the activity willingly?  Yes ☐     No ☐ - Did the client complete the activity without hesitation or question, or in hopes of receiving something in return?   Was the client being deceived/manipulated due to a scam?  Yes ☐     No ☐ - Did the client complete the activity due to believing a scam such as a romance scam, sweepstakes scam, overpayment for an item, etc.?   Is there a known suspect(s)?   Yes ☐     No ☐ - Suspect could be someone who defrauded the client via a scam or other means, or the suspect may be the client themselves (example: depositing an altered/fictitious check).     Please include any available identifying information for the known suspect(s): Include as much detail as possible for the suspect (name, address, DOB, SSN, driver’s license, phone number, email address, etc.)   Is the client age 60 or over?   Yes ☐     No ☐ - This section is to inform of possible concern of Elder Financial Exploitation.          If yes, has the activity been reported to the appropriate Department of Aging?    Yes ☐     No ☐                  If no, why is the client not being reported? Provide a reason the activity is not being reported, such as the client is not disabled in any way or is of sound mind, etc.                  If yes, list the contact information below: Select from the drop downs for DCF Contact Date and State the report is being filed with. Type in the contact agent name and phone number.
     DCF Contact Date: Click here to enter a date.	Agent Name:
     State Report Filed: Choose an item.	Agent Phone Number:
     Was Law Enforcement (LE) contacted by the bank?   Yes ☐     No ☐ - If Law Enforcement was contacted by the CLIENT, include any known information related to their report in the narrative section.           If yes, list the contact information below: Select from the drop down for LE Contact Date. Type in the contact agent name, phone number, and their department.
     LE Contact Date: Click here to enter a date.	Agent Name:
     Department:	Agent Phone Number:
     Narrative: Include Who, What, When, Where, Why and How. Include information on completed and attempted transactions.          *If there is supporting documentation regarding the investigation, i.e. prior email correspondence, transactional images, etc. please send the documents via email to _BSA Department.
     ONLINE DETAILS (Cyber Crime)   If business email compromise took place, how did the compromise occur? Be as descriptive as possible with how the compromise took place, and include any known details such as email addresses, phone numbers, mailing addresses, wire details, was the clients computer scanned, etc.   If the activity took place through an online channel, is there a known IP address? If the fraudulent activity took place via bank online transactions, emails to Capital City Bank, etc. is there a known IP address? If so, include the information.

      

      
2. Sign in to Verafin.
   • If the Verafin system is down, see the Disaster Recovery tab.
   • New Users:
     • Username - CCB email address
     • Temporary password - Password20+
     • For password resets of disabled users contact the Help Desk at ext. 397400.
3. In the menu bar on the left, click the Teller icon.  
   
4.  In the Teller Home screen, click Unusual Activity Referral.
   
5. Click Search customers.
   
6. Enter Client Name.
7. Click Select.
   
8. In the Referral Type field, use the drop-down menu to choose BSA/AML. 
   
9. In the Referral Details section type Fraud Referral.
   • The following details should be included either in the form, or in the Referral Details.
     • Client/Subjects Involved - The individual or entity that appears to have committed the fraud or caused the fraud to be committed. For clients, include name, Client Information File (CIF), and account number, and indicate if the client is a victim or suspect. For non-clients, include as much identifying information as possible (for example: name, date of birth, phone, email, address)
     • Narrative - Provide a summary of fraudulent transactions, accounts involved, and why the activity is fraudulent
     • Transaction List - List all fraudulent transactions, dates, and dollar amounts. Include the actual date of the activity, not the date charge-backs were processed. If there are more than 10 transactions, enter the transaction details (dollar amount and credit/debit) into a spreadsheet and include the spreadsheet with the UAR
     • Loss to the bank - Dollar amount for total losses
     • Law enforcement contact information (if any) - Agency name, contact name, phone number, extension, contact date, and a copy of the police report if applicable
     • Elder abuse information (if any) - Agency name, contact date, time, and copy of the report (or case number provided when report was filed) - see Reporting Abuse, Neglect, or Exploitation for more information.
     • Correspondence/Communication - Include attachments (preferred) or summaries of any communication with retail associates, clients, and/or any other person(s) involved in the fraudulent activity
10. Insert a screen clip of the entire completed Unusual Activity Referral Fraud Form.
    • Note: The drag & drop files feature does not work for this process. If additional files are to be reported to BSA, email _BSA Department.
11. Once all information is recorded, click Submit to send the UAR to the BSA Department.
    • If additional details are discovered after the UAR submission, send an email to _BSA Department indicating the new information.

If the Verafin system is down, associates must manually complete the disaster recovery UAR form and email the completed form to _BSA Department.

Click here to access the UAR form.