SAR
Question: We are having a debate about whether to file a Suspicious Activity Report on a customer. He is a foreign national who has several business accounts with us. He opened a new account with a substantial sum and does not want to order checks. He told us it is an investment account. He asked instead for counter checks. He has made several additional deposits but has not yet drawn any funds out by check or other means. When we suggest that he purchase checks, he becomes a bit hostile. We aren't quite sure what is going on and wonder whether this should be reported on a SAR.
Answer: Our general rule is that, when in doubt, it is better to file than not to file a SAR. Your situation is intriguing, however. It isn't yet clear whether your customer is up to something that he shouldn't be or whether what you are seeing is simply a cultural difference.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 4, 5/04>/span>
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