When the owner of an ATM resides in a state that requires the ATM be registered refuses to register that ATM; do you file a SAR on that customer for failure to provide documentation? If a SAR is required, does the continuous SAR filing rule apply until the customer complies?
If a SAR is filed, is it mandatory that any client accounts must be closed?
A person applies for a credit card at an issuing bank and the application is declined due to a fraud flag (Iocation IP address, prior fraud address, prior fraud phone number, etc) and the credit line that would have been assigned to the credit card account would have been $5,100. Would a SAR need to be written in this case due to the fact that there is a possible suspect with a possible usage of over $5,000?
A person applies for a credit card and it turns out to be a fraudulent application with a credit line of $5,100. No transactions take place on the card and the account is closed. Would a SAR need to be written in this case due to the fact that there is a possible suspect with a possible usage of over $5,000?
If a branch made us aware of Suspicious Activity, and we determine a SAR needs to be filed, would we mention the fact that we were made aware from a branch or just say we were made aware in general, should we ever get the branch involved.
When completing a SAR re-file, do you have to include the sum of all deposit or withdrawal activity during the re-file period even though only one transaction may be suspicious?
Is there any specific activity a safe deposit renter would do that would require us to file a SAR?
Our recent examiner said we must work up a potential SAR report for summonses & subpoenas. Does this apply if the subpoena is on a former customer (currently closed)?
Can SAR information be given to internal auditors? I have always been told to keep these strictly confidential.
A customer of country A is making payments on a monthly basis to a PEP from country B which is acting as Honorary Consul in country C. When asked the customer indicated payments are commissions for referring customers located in country C where he is acting as Ho. counsel. The reason of these payments is because they are long time friends (customer and PEP). Activity is suspicious and recommendation to file a SAR was made. However, legal counsel do not consider this suspicious. Please your comments.
I overheard an employee recommending to a customer to deposit part of a deposit one day and the rest of the money the next day, therefore avoiding the filing of a CTR. What action would need to be taken on this employee? I need to make sure that all the bases are covered and all the reports needing filed are filed.