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#1466633 - 11/10/10 06:02 PM SAR?
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
I'm torn on whether to file a SAR on a particular business customer. This business was recently shut down by federal authorities. Allegedly there are multiple counts of wrong doing, none of which I can see are directly financially related. However, it was noticed recently that they had an unauthorized signer endorsing their checks. Not something we would typically file on, however, the owner of this business has been convicted more than once in the past for embezzlement. Should I file even though the authorities are already on to them? My instincts are telling me yes.

Comments are appreciated!

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#1466657 - 11/10/10 06:40 PM Re: SAR? ComplianceGurl, CRCM
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
If you have found any evidence of wrong doing or suspicious activity in their accounts (which you apparently have for the unauthorized signer) you must file even though law enforcement is already involved.
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy

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#1466730 - 11/10/10 08:01 PM Re: SAR? Kathleen O. Blanchard
OldTeller Offline
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Joined: Sep 2010
Posts: 159
Do you have a basis for a suspiciousness determination?
Last edited by OldTeller; 11/10/10 08:01 PM.
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#1466763 - 11/10/10 08:36 PM Re: SAR? OldTeller
ComplianceGurl, CRCM Offline
Gold Star
Joined: Jul 2007
Posts: 498
At the time I noticed the unauthorized signer activity, no, I was not suspicious. Then I found out about their business being shut down by the DEA and the embezzlement convictions...that made me wonder. Normally I would not file just because they had an unauthorized signer endorsing checks, unless of course it was a fraud issue.

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