On the SAR, box 35, letter O, refers to misuse of postion or self-dealing...I am looking for a definition of self-dealing. Would that only refer to something within the institution, or could it refer to a POA who tends to make many cash withdrawals or cash checks, from the principal's account, payable to himself/herself?

I believe the Misuse of Position or Self Dealing covers internal matters and bank employees. Self Dealing would cover, for example, a loan officer that has an interest in a piece of property for which he/she has made a loan.

SAR filing for "insider abuse" does not apply to the actions of customers. This reporting is required by the bank regulatory agencies not FinCEN. Here's an excerpt from the FDIC's regualtion:

((1) Insider abuse involving any amount. 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 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 the bank has a substantial basis for identifying one of the bank's directors, officers, employees, agents, or other institution-affiliated parties as having committed or aided in the commission of the criminal violation, regardless of the amount involved in the violation;

Does there have to be a violation of law for an SAR to be filed on an officer for self dealing? For example, an officer getting a kickback on some business dealings of a customer in which the officer gave advice?

Unless a law was broken, it would not constitute a SARable event. However, I am sure it would be a serious violation of your code of conduct and result in termination.

You should check with legal counsel, however, regarding whether the particular action was illegal. It might have tripped a RICO trigger, could constitute wire fraud if any of the transaction took place via telephone (!). I am amazed how many criminals are tripped up on wire fraud and it involves phone or fax transactions.

That was me. Not sure why I was signed out!