What is the dollar limitations for filing a SAR?

They are right on the form.

i figured as much, thought someone could just raddle it off

FNBBangor, do you mean the thresholds? For banks it's aggregate $5,000.00.

Unless an insider or unless there is an unknown suspect or it involves computer intrusion........

• Insider abuse involving any amount

o A SAR is required whenever the Bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the Bank or involving a transaction or transactions conducted through the Bank, where the Bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations, or that the financial institution was used to facilitate a criminal transaction, and the Bank has a substantial basis for identifying one of its directors, officers, employees, agents or other Bank-affiliated parties as having committed or aided in the commission of a criminal act regardless of the amount involved in the violation.

• Transactions aggregating $5,000 or more that involve suspected potential money laundering or violations of the BSA

o Any transaction conducted or attempted by, at or through the Bank and involving or aggregating $5,000 or more in funds or other assets, if the Bank knows, suspects or has reason to suspect that the transaction. Involved funds derived from illegal activities or is intended or conducted in order to hide or disguise funds or assets derived from illegal activities (including, without limitation, the ownership, nature, source, location, or control of such funds or assets) as part of a plan to violate or evade any law or regulation or to avoid any transaction reporting requirement under federal law;
 Is designed to evade any regulations promulgated under the BSA; or
 Has no business or apparent lawful purpose or is not the sort in which the particular customer would normally be expected to engage, and the institution knows of no reasonable explanation for the transaction after examining the available facts, including the background and possible purpose of the transaction.

• Violations of federal criminal law aggregating $5,000 or more where the suspect has been identified

o A SAR will be prepared whenever the Bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the Bank or involving a transaction or transactions conducted through the financial institution and involving or aggregating $5,000 or more in funds or other assets, where the Bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations, or that the Bank was used to facilitate a criminal transaction, and that the Bank has a substantial basis for identifying a possible suspect or group of suspects.

• Violations of federal criminal law aggregating $25,000 or more where the suspect is not known

o A SAR will be prepared whenever the Bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the Bank or involving a transaction or transactions conducted through the Bank and involving or aggregating $25,000 or more in funds or other assets, where the Bank believes that it was either an actual or potential victim of a criminal violation, or series of violations, or that the Bank was used to facilitate a criminal transaction, even thought there is no substantial basis for identifying a possible suspect or group of suspects.

Is there a consensus that if we had a commercial customer who had a stack of payroll checks stolen, we cashed an aggregate total of just over $5,000 before we figured out what was happening, and the suspects were caught in one of our drive-thrus by the police as they attempted to cash some more, a SAR should be filed? Our Security Dept is very territorial and I have a VERy difficult time getting information from the.

Since you know who the suspects are - a SAR would be required.

It may help with other investigations if this turns out to be a "ring".

Absolutely and in the total you will include any checks they "attempted" to cash. The SAR is not based solely on the bank's loss, rather what was conducted and attempted at or through your institution. You may also want to ensure you don't have additional unreported situations that warranted SAR filing sitting in a drawer somewhere. (Can you say "AmSouth"?)

That's what scares me.................since one department is so territorial and seems unwilling to share information, I'm afraid to guess what might be in a "drawer" somewhere that I'm not even aware of. It was only because I happen to see an alert go out to all employees that I was aware of this one!
And it was sent by a branch person, not that "other" department.

That is your favorite phrase!!

When it comes to a disconnect between "fraud" and "BSA"--you betcha! It was an expensive lesson, well worth learning. I wouldn't want to have to write a check with that many zeros!

oh yeah, I understand that disconnect and the 'territoriality'--

This needs to be brought to the attention of management and possibly the board of directors. To paraphase Reagan "tear down this wall"! The BSA, security and fraud departments need to be in lockstep in order to protect the bank.