What is Suspicious?
The difficulty in filing SARs lies in deciding what is suspicious. Every now and then there may be an obvious attempt to launder money or support terrorist activities. But more often, the activity is more subtle. The key may be simply that the amount and movement of money doesn't seem to fit the business. FinCEN reports that one SAR filed was based on the fact that the customer was moving significant amounts of money to businesses that appeared to be inconsistent with the customer's stated business. This type of activity is identified through CIP and risk monitoring, so stay alert.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 7, 6/05
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