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#1083645 - 11/18/08 08:39 PM SSN to ITIN - $ for SAR?
SARempress Offline
Junior Member
Joined: Jul 2006
Posts: 37
Deep in the Heart of Texas
We had a customer who recently provided a ITIN to replace the SSN that he's been using on his accounts with us since 2006. We determined that the SSN appears to belong to a deceased individual. Pretty sure we should file a SAR (since this is an example of suspicious activity from the FFIEC manual), but what amount do I use?

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BSA/AML/CIP/OFAC Forum
#1083795 - 11/18/08 11:51 PM Re: SSN to ITIN - $ for SAR? SARempress
smash Offline
Gold Star
Joined: May 2004
Posts: 331
Texas
I wouldn't and don't. We have similar circumstances here from time to time. They are undocumented aliens who were hired by a dairy and given a number to use. They didn't know at the time what that meant. Now they understand and have done what they should have done to start with. As far as we are concerned, now we are able to better identify them for CIP and are in compliance.

I know there will be SEVERAL who vehemently disagree with me, Besides, "immigration violation" is not a category on the SAR. And yet again, there will be some who say, "Duh! What do you think "Other" is for?

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#1084134 - 11/19/08 04:23 PM Re: SSN to ITIN - $ for SAR? smash
YosemiteSamIAm Offline
Power Poster
Joined: Jan 2004
Posts: 2,795
Guess
I most certainly disagree. How do you know they did not know what they were doing at the time? What else has that SSN been used for that you don't know about, but law enforcement or some other business/individual does need to know about? What debts/obligations are they going to be able to avoid now(child support/garnishment)? I certainly would agree that we probably have too many laws in this country, but this is one about which I don't think I want to argue with an examiner about why I didn't file.

Oh, and to answer the original poster's question, I would try to ascertain the amount of dollar deposits that went through the account from setup to SSN change and use that amount.
Last edited by Coloradomountainman; 11/19/08 04:27 PM.
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