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#1459305 - 10/25/10 10:29 PM SAR filing

A SAR was filed on a customer for transactions that occured in June and July. We have received information that this customer is committing fraud and has additional transactions in September and October.

Can we file another SAR now including the September transactions? Since we have received information (from a reputable source) this customer is committing fraud does the 90 day timeline even apply?

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#1459313 - 10/25/10 11:57 PM Re: SAR filing Anonymous
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,277
Yes, you don't have to wait. If you have additional information that would aid law enforcement you should file sooner rather than later.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#1459568 - 10/26/10 04:28 PM Re: SAR filing Kathleen O. Blanchard
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 39,641
Cape Cod
If the customer is committing fraud, I'd get that SAR out as soon as you can assemble the information, and give the customer the boot as soon as possible. You don't want any of the fraudulent actions of your customer coming back to involve the bank in a loss or risk of a besmirched reputation (for banking the SOB).
John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1459585 - 10/26/10 05:01 PM Re: SAR filing John Burnett
Midwest Banker Offline
Gold Star
Joined: Nov 2004
Posts: 349
If you know that a law enforcement or federal agency is investigating them, after you file the updated SAR, you may wish to give them a call as well. .

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