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#1093200 - 12/08/08 01:48 PM SAR necessary??
AuditorK Offline
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Joined: Feb 2003
Posts: 962
PA
We have a business customer who is under investigation by the IRS. In speaking with someone at the IRS, the business is being looked at for possible tax evasion. We have just received a levy and summons for account information. We haven't noticed anything suspicious with this customer's account. I'm thinking we don't need to file a SAR on this customer. First, we haven't detected anything suspicious to report, other than receiving the summons from the IRS. Second, if the purpose of a SAR is to notify the proper authorities, it appears that they are already on to this customer. Does anyone have an opinion they would like to share?

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#1093219 - 12/08/08 02:12 PM Re: SAR necessary?? AuditorK
rlcarey Offline
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rlcarey
Joined: Jul 2001
Posts: 83,219
Galveston, TX
" First, we haven't detected anything suspicious to report, other than receiving the summons from the IRS."

That says it all. Reviewing accounts after receiving such information should be part of your monitoring processes, but after a review and you see nothing from your end, there is no requirement to file a SAR. It should be maintained in your "decisions not to file" documentation.
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#1093443 - 12/08/08 06:16 PM Re: SAR necessary?? AuditorK
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Originally Posted By: AuditorK
Second, if the purpose of a SAR is to notify the proper authorities, it appears that they are already on to this customer.


Be careful ... never use that as a reason you didn't file a SAR. It is how other banks got very large fines.
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My opinions are my own, and not that of my employer.

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#1093455 - 12/08/08 06:22 PM Re: SAR necessary?? WonderWoman
AuditorK Offline
Platinum Poster
Joined: Feb 2003
Posts: 962
PA
Thank you both for your good advice!

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