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#373545 - 06/15/05 09:16 PM SAR filing
BankerKB Offline
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BankerKB
Joined: Jan 2005
Posts: 288
Does anyone have something that lays out more clearly when you need to file a SAR? We had a customer A that reported another customer B was trying to confuse them into giving them access to their bank account. Both are our customers. Customer B who was reported as trying to commit fraud only had about $500 with our bank. Would this not need a SAR filed then because it is under the $5000 limit. I was told that unless he has violated the law and the amount of the violation is over $5,000 or he is committing mortgage fraud, which we do not know, no SAR would need to be filed? I am new to this and need some guidance. Thanks!
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BSA/AML/CIP/OFAC Forum
#373546 - 06/16/05 12:28 AM Re: SAR filing
Anonymous
Unregistered

A SAR is not necessary. But you should always document your reasons for not filing a SAR.

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#373547 - 06/16/05 01:13 PM Re: SAR filing
BankerKB Offline
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BankerKB
Joined: Jan 2005
Posts: 288
Does anyone have a copy of what they consider to be acceptable documentation for suspicious activity or want to share how they track it and decide whether to file or not.
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#373548 - 06/16/05 07:31 PM Re: SAR filing
GregS Offline
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Joined: Jan 2005
Posts: 135
Sunny Florida
I'm not sure you will find a "list" of SAR filing reasons. If there were one it would probably read like the Federal Register.
We use our Prez, CFO and myself (BSA Officer) as a SAR Committee. Policy says we may also use counsel if we need to. Most communications are e-mail and I keep them all as well as notes of all my phone calls. We report the facts only to the BOD for all filings.
The committee, the filings and the non-filings were praised by FDIC. I marked it on the calendar.
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#373549 - 06/21/05 02:15 PM Re: SAR filing
BankerKB Offline
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BankerKB
Joined: Jan 2005
Posts: 288
Thanks that is helpful. We report ours to the board as well. I guess I was wondering what documentation you hold onto for your own purposes when you investigate.
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#373550 - 06/28/05 08:19 PM Re: SAR filing
BankerKB Offline
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BankerKB
Joined: Jan 2005
Posts: 288
I also found this website link which is good for SAR.

http://www.fincen.gov/narrativeguidance_webintro.pdf
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