SAR Filing For Suspected Teller Theft
by Mary Beth Guard, BOL Guru
Question: We have a teller that we need to terminate. She has been short several times in her cash drawer recently. Each time, the amounts were under $1,000. She has no explanation. Do we have to file a SAR? Is there a penalty for not filing a SAR?
Answer: Yes, you are required to file a SAR. This would be considered suspicious activity involving an insider and there is no dollar amount threshold for that. When it involves an insider, you must file the SAR on the suspicious activity regardless of the amount.
There is a penalty for not filing. The amount depends upon all the circumstances, but I would strongly urge you to file. This is a clear cut case where filing is required. Think about the fact that she may end up getting employed by another financial institution and doing the same thing there. Your filing puts FinCEN on notice and could potentially head off future losses by other institutions.
The original version appeared in the September 2002 edition of the Oklahoma Bankers Association Compliance Informer.
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