I'm working on a SAR where a customer came in, visited their safe deposit box, then purchased a large cashier's check. We don't know if the funds came out of the SDB, but assume at least a portion did. Already determined that a SAR needs to be filed because their explanation of the funds and purpose of the MI purchase does not match their previous account history nor the payee on the check.

Anyway, I am going to list the SDB in the narrative but am unsure if I should list the SDB number as an account involved in the suspicious activity on item 24.

Advice?

It would be based on your agreement, I believe. Our agreement says "SDB Rental", so we don't list SDB number as an account but rather mention it in the narrative. I do put SDB number on SAR log for convenience (and to show right away that SDB activity is monitored:)), and the auditors seem fine with it.

A SDB is not an account - deal with it in the narrative.

(a) Account. For purposes of §1020.220:

(1) Account means a formal banking relationship established to provide or engage in services, dealings, or other financial transactions including a deposit account, a transaction or asset account, a credit account, or other extension of credit. Account also includes a relationship established to provide a safety deposit box or other safekeeping services, or cash management, custodian, and trust services.

If your boxes have account numbers, include them.

I knew we treated SDBs as accounts for CIP. Probably why I was wondering if the SDB would be listed as an account to be listed in Item 24.

Thanks so much for your help.

Customer comes in and visits SDB. Goes from SDB to teller line and deposits $9,900 and is holding additional $100 bills in hand. Customer makes statement that someone is watching them because they think they are drug dealers. My question relates to the above- we have numbers on our boxes and they are given to the customers.
1) Do I include the number as an account in line 24?
2)If I include this as an account in line 24 should I also check box 33h-suspicious use of multiple accounts?
3)If I don't include this as an account in line 24 should I still check box 33h and explain this in the narrative?

any help will be appreciated.

I'm making this up: If I can look up a safe deposit box on your computer system, it must have an account number. If so, I would include it in Box 24.

Either way, I would include the box number and location in the narrative.

I don't see any argument for suggesting there are multiple accounts involved.

If you want to be sure, call the Helpline and tell them what you intend to do. Then, do what they say.

That makes sense Ken. Thank you very much for the insight. Very helpful as always

I called the Helpline and their response mirrored Ken's thinking. If it is an account number that is searchable on our system, include it. If the assigned number is for reference only, don't include it on item 24 and mention it in the narrative.