Obtaining Information for a SAR
Answer by John Burnett and Ken Golliher, BOL Gurus
Question: If a customer is not to know that you are completing a SAR, how do you get personal information from them to complete the form? We may not have all the information required on file, such as DL #, etc.
Answer by John Burnett: BIO AND CONTACT INFO
Imagine - "Excuse me, but I need some personal information about you. No, I can't tell you what it's for. But I really need it!"
Of course you wouldn't dream of having such a conversation! And you shouldn't. If you don't have a piece of information requested on the SAR, and you can't find it anywhere in your files, you'll have to omit it. The SAR rules are not so strict as those for CTRs.
But the more ID and other information you can provide, the better information law enforcement will have if they use your SAR in their investigation. So be diligent, but don't "tip your hand."
Answer by Ken Golliher:BIO AND CONTACT INFO
John's right about not "tipping your hand." I think the folks who designed the form reasonably expect that if the suspect is a customer, you will have the identifying information.
With other suspects you might not have it. That makes it doubly important to provide any information that might lead law enforcement to that person, such as the name of the bank and the account number on a check that person gave you, a telephone number, credit card number etc. in the narrative portion of the SAR.
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