We have two individuals that cashed fraudulent checks against the same bank customer. Aggregate of all checks cashed is over $5,000, however per individual they do not meet the $5,000 threshold. We want to file SARs my question is 'Can I file one SAR with the two suspects together or does it require individual SARs for each? Thanks.

Remember, the bank may file for any amount, but is required to file when the threshhold figures ($0 insider, $5k for know suspects, $25k unknown suspects) are reached.

IMO, you could probably file either way, however, I would file a single SAR. Although you have two separate transactions, either of which may be reported separately, you have an aggregated amount exceeding the dollar trigger which must be reported.

see 31 CFR 103.18

"§ 103.18 Reports by banks of suspicious transactions.

(a) General. (1) Every bank shall file with the Treasury Department,...a report of any suspicious transaction relevant to a possible violation of law or regulation. A bank may also file...a report of any suspicious transaction that it believes is relevant to the possible violation of any law or regulation but whose reporting is not required by this section.

(2) A transaction requires reporting under the terms of this section if it is conducted or attempted by, at, or through the bank, it involves or aggregates at least $5,000 in funds or other assets, and the bank knows, suspects, or has reason to suspect that:..."