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#1126044 - 02/09/09 05:37 PM Special Agent Requesting SAR Info--HELP!!!
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
I am a little confused on this one... A special agent with ICE called asking for information regarding SARs on an individual that I have filed. He said he didn't have the SAR but he did seem to have information that I had in my narrative(s). I told him I needed something in writing on US Immigration and Customs Enforcement letterhead to obtain information. He is requesting copies of all SARS that I have filed on this particular individual. I'm just wondering how he would know anything about this without actually having copies of the SARs?? Seems suspicious...or am I just being too cautious?

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#1126064 - 02/09/09 06:00 PM Re: Special Agent Requesting SAR Info--HELP!!! ComplianceGurl, CRCM
Comply 101 Offline
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Comply 101
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Posts: 708
Are they requesting copies of the SARs or the documentation attached to the SAR? They should have access to the SAR, how else would they know you filed one. I have had the IRS request the documentation attached to the SAR and they have always come with a written request, so that is ok to ask. Just remember to not provide them any information that would fall outside your SAR filing. That would require a subpoena.
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#1126073 - 02/09/09 06:04 PM Re: Special Agent Requesting SAR Info--HELP!!! Comply 101
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
He is requesting the individual's full name, address, DOB, spouse's name, and a few other things that would be in the SAR. He is also asking for copies of the SARS and any other information that I feel would help him determine if an investigation should be initiated. This is why I'm confused...the information he is asking for is in the SAR. Also, he knew of some details that he wouldn't have known had he not read the SAR. I'm very confused. I have left a message for FinCEN.

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#1126144 - 02/09/09 06:38 PM Re: Special Agent Requesting SAR Info--HELP!!! ComplianceGurl, CRCM
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
I wouldn't give him anything until you confirm his identity. If it is legitimate, he should be able to provide you something that states it is a legitimate request.

If you are an OCC Bank, OCC bulletin 2007-37 addresses this.
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#1126151 - 02/09/09 06:43 PM Re: Special Agent Requesting SAR Info--HELP!!! J2C
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
On the "other end" of a SAR, all the investigator sees is your whole narrative in one long continuous line. It is very difficult to read. The initial investigator probably pulled the info - then forwarded to the ICE guy that called you. They often ask for the SAR itself because most of the time it is MUCH easier to read.
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#1126218 - 02/09/09 07:31 PM Re: Special Agent Requesting SAR Info--HELP!!! WonderWoman
luvflipflops Offline
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Joined: Nov 2005
Posts: 150
on a beach somewhere
The FFIEC's BSA/AML Manual is very clear in stating that no legal process is required for disclosure of supporting documentation to FinCEN or an appropriate law enforcement agency. Supporting docs are defined as all docs or records that assisted a bank in making the determination that certain activity required a SAR filing. Even though most of the time, the supporting docs should be mentioned in the SAR, if it isn't and you used it to determine the SAR should be filed, it is also available for request by LE. I would always verify who they are.

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#1126260 - 02/09/09 08:13 PM Re: Special Agent Requesting SAR Info--HELP!!! luvflipflops
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
Thank you all for your input!!! I verified that it was a legit request. Newbsa, I didn't realize how the investigators viewed the narrative. That would then make sense why he knew some things and not others.

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#1126268 - 02/09/09 08:25 PM Re: Special Agent Requesting SAR Info--HELP!!! ComplianceGurl, CRCM
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I was invited to the department (RTTAC) that investigates SARs in Northern California & they held a "class" on what they see and what things help a case.

It was extremely interesting & involved all Law Enforcement & NO REGULATORS!! smile

If any of you are in CA & can make it to the Sacramento area ... check out http://www.infragard.net/chapters/sacramento/ (Or PM me & I can give you more specific information)

or if you are in the Northern California Territory (San Francisco - & "green" belt) check out https://ncrttac.org/
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#1126531 - 02/10/09 05:47 AM Re: Special Agent Requesting SAR Info--HELP!!! WonderWoman
cbinder63 Offline

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cbinder63
Joined: Dec 2001
Posts: 674
Colorado
We also had a similar seminar in Colorado. It was enlightening to see how antiquated the narrative shows up to LE.
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#1126539 - 02/10/09 11:34 AM Re: Special Agent Requesting SAR Info--HELP!!! cbinder63
rlcarey Online
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rlcarey
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Galveston, TX
Actually, the narrative shows up just like it is placed on the SAR, minus paragraphs, etc. That is why it is suppose to be a narrative format and not a bunch of tables and whatnot. The junk that some of the automated SAR preparation systems (not mentioning any vendors names here) are the worse when they pre-generated a bunch of tables of information for inclusion.
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