If your normal procedure was to have all SARs filed by the BSA Officer and the CEO came to you asking you if he could file a SAR himself. What would you do? It sounds like he wants to file a SAR on an insider relationship but wants to keep it confidential. I don't know whether to feel insulted or grateful if I am not involved. Anyone had this situation come up before?

I once dealt with a bank whose CEO did it without asking:

When they were examined the examiner began cross examining the BSA Officer (a very good one) about the filing and it was clear she did not have a clue what he was talking about. So, he showed her the copy from the data base. She was embarrassed and slightly miffed.

The regulator made the obvious observation in the written report: The bank did not really have a demonstrable policy and procedure for filing SARs because this one was filed contrary to every written statement the bank had made about its processes.

You're in a difficult spot, but you need to go back to the CEO and point out the problems with departing from written commitments. In addition, it will have to be reported to the board, it will have to be retained with the other SARs, etc. Also note that your BSA auditor will need to see it at some point as well.

"SAR confidentiality" does not suggest that only one person in the bank should know about a SAR.

Thank you, Ken! I think my gut was telling me the same....follow the policy and do things right. I will only have myself to blame if I try to circumvent the policy to please the CEO and his confidentiality concerns and it results on the bank's or my embarrassment later on.