We received a subpoena requesting account information for the account of an Indian Tribe. It was a federal subpoena. Our outside legal counsel discussed the subpoena with the agency involved primarily to get us some extra time to compile the records. In the course of the conversation, the agent stated that the investigation was due to misappropriation of funds. In reviewing the account, I can't see anything that would jump out as a red flag for mishandling of funds --- but I also don't know that much about tribal governments or structure. Do you think I should file a SAR anyway??

If the fact that you received a subpoena caused you to review account records, and that review led you to believe that funds may have been misappropriated, you should file. You certainly can review the records internally with someone in your organization who might have a better feel for tribal finance.

If, on the other hand, your review comes up empty, I suggest you document your reasons for not filing the SAR, and move on. If you later learn or decide that the account was involved in misappropriation of tribal funds, you can then change your mind and file then.