When preparing a SAR narrative, if the business account relationship contains multiples accounts (at least 8) and the suspicious activity was only detected on two, are we permitted place emphasis on those affected accounts and establish that none of the remaining accounts had flags or suspicious activity detected?
My question is in regards to a returned item and the date that should be reported on the SAR. We were recently advised that the suspicious date for the returned item should be the date of the original deposit and not the date it was returned. But isn't the item being returned the suspicious nature of the transaction so shouldn't we use the returned date instead?
As it pertains to the FinCEN guidance in 2016 relating to Cyber-events and Cyber-enabled crime, does the requirement of identifying a suspect still apply, or should banks be filing SARs on cyber-enable crime(i.e., identity theft) if the $5k threshold is met even if a suspect is not identified?
Can Financial Institutions disclose on a SAR that a subject appeared on FinCEN's 314a list?
Is a canabidiol (CBD) business legal at the Federal level. I understand it is legal in all 50 states but unsure about the Federal level. Would it be treated the same as a marijuana related business where a continuing SAR would be required?
Are there any rules that would prevent us from reissuing a cashier's check every few months for a customer? She comes in and wants a fresh check but never cashes it out. Is that a reportable suspicious activity? Are we breaking rules by doing this?
When doing a SAR renewal if new activity is discovered along with continued activity of previous filed SAR can the new information be included in the renewed SAR or must a new SAR be completed with the renewed SAR only containing the continued activity?
Where can I find an updated definition guide for the suspicious activity categories of a SAR?
What does our regulator mean by "most recent report for SAR /CTR filed along with 3 years filing trend"?
I was told by an examiner a few years ago that a bank is not required to report a SAR to its Board of Directors if the SAR involves a member of the Board. That provides protection for the person filing the SAR. Is that correct? If yes, where can I find that information? Thank you.