Hello -

Recently a question came up in our Ops as to who should file a SAR. I stated that the BSA/AML Officer should be the one to file while the other person maintained that if needed, the branches should be able to. I somewhat agreed to him but we both came to the conclusion that instead of the branches each filing, making it difficult to follow up on SARS since they are supposed to confidential, we should have a type of referral sheet that the branch staff can fill out and submit to the BSA/AML Department for review and they can deem whether or not a SAR should be filed. This leads me to the reason for this post...

Does anyone use a referral or something similar? If so, would anyone be willing to share it with me just so I can have a starting point?

Thanks!

Yes - We have what we call a SARF (Suspiciosu Activity Referral Form) It is to be completed by anyone in the branches or bank that comes across anything unusual or suspicious during their daily work. It is confidential and does not require any kind of approval to be sent. Simply receiving a SARf doesn't not mean an automatic SAR will be completed, it's simply the first step in an investigation process. If we investigate and find the activity reported to be factual we file if we dont we do not and we documet our reasons why.

Hope this helps

We also have a similar form. It is very basic (1 page) and all it asks for is a little info on the cusomter (name, account number, etc.) and a brief narrative of what activity the reporter considered supsicious. The BSA Department takes it from there!

We also have a form on our intranet that is emailed to the SAR committee for action.

We use an Unusual Transaction Form for reporting of unusual activity to the AML Dept. I would never design a process that allows a routine SAR to be submitted by anyone other than the AML Dept. through its centralized process to ensure appropriate investigative measures have been taken, documentation is consistent with bank policy and follow up has been established if necessary. There should be established procedures for filing outside of this process if persons involved in the "routine" process are the subject of the SAR.

Ms.Mia, that is exactly what we do too. I also keep a pretty log to prove to our regulators that we made a SAR/No SAR decision within 30 days of the initial detection.

We do too it's very helpful when they're asking for a millio and one things LOL

Thanks for all your help! I have created a referral form based on all of your suggestions and we are introducing it today!

we have a form. i would in no way advocate a branch filing a SAR. a referral for a SAR, yes but not the actual filing.