I don't believe you will find any specific instructions on this point. However, in my opinion, the advice you received is sound. Whether the account is a business or personal account, including information on the signatories is advisable.
In the case of the business, obviously it was not the corporation that structured the transactions, it was the people involved. Without their information, no connection can be made to other activities they have been involved in.
In the case of a joint account owned by individuals, if one of the owners is structuring transactions law enforcement personnel are pretty quick to say the other party knew or should have known that the activity was taking place. (If you and I own a joint bank account, it's pretty reasonable to assume we have a close connection to one another.)
It's important to think of the SAR as not just a report on a particular event, but as an incremental addition to a data base. Law enforcement does a great deal of "data mining" looking for names, SSNs, addresses etc. that have been used in the past by people they are looking for. Your SAR may be on a fact situation that does not pique their interest. However, if it contains identifying information that a someone who is the object of an active investigation has used in the past, they may beat a path to your door.
Last edited by John Burnett; 04/30/05 06:06 PM.
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