To SAR or Not?
Recent developments in enforcement actions that were taken because institutions failed to file SARs have raised concerns about where to draw the line. Speakers at ABA's NRC conference provided some useful guidance. They noted thatin the "failure to file" cases the investigators found the banks in question through filings from other institutions and through other information generated by investigations. If your institution is reluctant, it is worth considering whether the same form of unfortunate discovery could happen to you. It is probably best to use Rick Small's principle: when in doubt, file.
Copyright © 2004 Compliance Action. Originally appeared in Compliance Action, Vol. 9, No. 7, 7/04
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