I need some help in completing a SAR. Have a customer that owns a clothing business. He was selling fake goods and was arrested. His customers who purchased the fake goods were giving him checks payable to him and and not to the business. He was coming to the bank and was cashing the checks. This was a way to avoid paying taxes on the sell of the goods.

He has three loans with bank and is named on a CD as payable on death.

My question is in the SAR do I include the loans and also the CD even though he is not the owner of the cd but is POD on the CD

Thanks

I would mention the loans in the SAR narrative (e.g., In addition, the customer maintains three loans with the bank; activity in the loans does not appear suspicious at this time).

I think this is a Dealers choice...

I might include only the loans and the CD in the narrative. But you could certainly include them on the lines of "Accounts affected" if you so choose.

Really the SAR should include all relevant ifnormation pertaining to the suspcious activity. If you think the customers entire relationship is corrupted or part of the tax evasion issue than I would certainly include in at least one of the places as it is material.

Cheers!

If you suspect the loans are in any way connected with the suspicious activity, I would include details in the identifying info for SAR. If not, I would mention in the SAR narrative.

I would not document the POD as he is not the owner of those funds (unless, of course, I had reason to suspect he was the true owner and he had someone set up for him to hide the money).