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#2015411 - 05/21/15 02:27 PM SAR Suspects
blight1969 Offline
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Joined: Mar 2015
Posts: 2
I need some opinions. I have a situation where the account involved in the suspicious activity is a joint account. The primary is the one coming to the branch and conducting the suspicious activities (structuring). I feel that because the joint owner has the ability to reap the benefits of the activity that they should be included as a suspect as well especially seeing as they are the spouse. Should I include the joint owner as a suspect?

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#2015422 - 05/21/15 02:42 PM Re: SAR Suspects blight1969
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
If they are not the individual actually conducting the transactions, I generally do not include them as a suspect. If I feel the need to mention the spouse I usually do that in the narrative, and include all of their identifying information. You may want to call FinCEN's helpdesk and get their opinion and document what you were told.
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#2015445 - 05/21/15 03:35 PM Re: SAR Suspects blight1969
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 681
I also focus on the person that is doing the suspicious activity and as the suspect and in the narrative I mention that it is a joint account with Jane Doe.
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#2015523 - 05/21/15 06:55 PM Re: SAR Suspects blight1969
thisisme08 Offline
Junior Member
Joined: Oct 2012
Posts: 47
^What she said.
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#2015567 - 05/21/15 07:52 PM Re: SAR Suspects blight1969
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
Opposite for me.
On a Joint account I always put both parties as suspects.
The Narrative tells the story of who did the transaction.

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#2015681 - 05/22/15 02:46 PM Re: SAR Suspects blight1969
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
As you note, you're seeking opinions; there is no official guidance.

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#2015955 - 05/26/15 03:48 PM Re: SAR Suspects blight1969
stressedout Offline
Member
Joined: Mar 2015
Posts: 93
This is a case by case decision for me. If I feel that the spouse is involved then I include as suspect, if not then I include them in the narrative as part of a description of an account. I feel that way any person reviewing the form that decides to investigate will not be surprised to see a joint owner.

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