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FBI Letter Response to SARs

Question: We have been getting letters from the FBI about the SARs we have filed. The letters look like form letters and explain that the situation we filed on does not meet their investigation threshold. This is getting really frustrating and my management is questioning why we do all this work when the FBI doesn't want it.

Answer: This letter really falls into the "you-asked-for-it-you-got-it" category. Remember when the industry complained that they never knew what happened to the SARs that were filed? Well, this is the FBI's way of letting you know that they got it. Creative writing is not in an FBI agent's job description. Sure, the letter is boiler plate, and there are good reasons for this. First, you don't want the FBI spending time writing individual letters to every institution that files a SAR. That would be a huge waste of time.

Second, did you really expect a letter that thanks you for letting the FBI know about a suspicious situation and that they are actively looking into it, thanks to you? What would your front line staff do the next time that customer came in?

Finally, there is more than one law enforcement agency. Just because the FBI isn't looking (or that is what they told you) doesn't mean someone else isn't using your SAR. Law enforcement has repeatedly said that the financial industry's reporting through CTRs and SARs is one of their most important investigative tools. Each SAR becomes part of an actively used data base. It is not often that a government entity thanks an industry for compliance, but law enforcement agencies have thanked the financial industry repeatedly. And they want you to keep up the good work. So please do just that.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 7, 6/05

First published on 06/01/2005

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