SAR Threshold and Trigger

Question: We have a customer whose behavior is suspicious. However, there is no loss to the bank. We can't decide whether to file a SAR as several people believe that we haven't met the $5,000 threshold. What should we do?

Answer: First, the threshold. The filing thresholds for known and unknown suspects trigger mandatory filing. However, you may always file when less money is involved - or known about. Now for the loss issue. Financial loss to the institution is not a prerequisite for filing a SAR. The suspicious activity is the trigger. The steps you must take include evaluating the customer's activity and determining whether it is suspicious. If so, you report it. You must report if you know who the suspect is and the funds involve $5000 or more. You may report it if the amount is less than $5,000. But financial loss to the institution is not one of the criteria.

Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 8, 7/05