Does Bank File SAR for Scammed Customer? - Ken Golliher

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Does Bank File SAR for Scammed Customer?
Answer by Ken Gollliher, BOL Guru
Guru BIOS

Question: We have a customer who sent an outgoing wire transfer to an out of state bank to purchase a motorcycle. He went to pick up the motorcycle, and the seller did not show. He has filed charges against the person the wire was sent to. Do we need to file a SAR? The bank is not out any money, just the customer.

Answer:I can't respond to this specific situation because I do not know the dollar amounts involved or whether you have a suspect. However, the general answer is, "Yes, if a threshold for SAR filing was met, you would file a SAR regardless of whether the bank was the intended victim." Several of the SAR filing omissions cited as the basis for criticizing AmSouth focused on fact situations where the bank was not the intended victim. Whether the bank actually lost money is not relevant to any SAR filing decision.

First published on BankersOnline.com 5/16/05

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