Skip to content
BOL Conferences
Thread Options
#353764 - 04/30/05 12:50 AM SAR Identifying Suspect
Anonymous
Unregistered

In the SAR narrative, we are supposed to describe the who, why, when, where, what and how of the suspicious activity. I attended a teleconference last month where the speaker stated we should "add signer information for all signers" when describing "Who is the suspect?". Following this advice, if we have a joint deposit account and one owner is coming in frequently with cash deposits of $9,900, and we suspect him of structuring; are we required to add the other owner of the account in the narrative and/ or as a suspect? The other owner may not even be aware of the structuring transactions. Or perhaps the speaker was refering to including signer information on business accounts, when the business is suspected of something suspicious. Any body else run into this question?

Return to Top
BSA/AML/CIP/OFAC Forum
#353765 - 04/30/05 11:32 AM Re: SAR Identifying Suspect
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
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.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top

Moderator:  Andy_Z