Hypothetical question...
Board member owns several businesss. two deposits on consecutive days under CTR threshold made by employee of one business. Not typical activity. funds then paid out for real estate transaction. If I were to file a SAR would I be required to note in the narrative that the business belongs to one of our directors? I am not certain that said director is aware of the manner in which the transactions were conducted. Curious what others would/have done in similar situations. Again purely hypothetical, idle curiosity...

Whenever we file a SAR on a company we include the authorized signers and any others involved as suspects with the understanding that entities don't structure, people do. If 1 of the individuals is a director I would mention that fact in the narrative even though he/she might not have been aware or involved. I would not necessarily check box 31 on the SAR unless I believed that the director was aware or involved. These are just my opinions.

Devsfan's practice is both prudent and common. If it was the way you had done things in the past, you would do it in this instance as well. If your past SARs have not mentioned signatories and principals, then you would not need to change it solely because one of the principals was a board member.

I'm glad you are not really facing this situation because asking the question proves you already understand that any third party reviewer could make a big deal out of the fact that you did not mention that a director was involved. On they other hand, your CEO could make a big deal out of the fact that a board member was "outed" gratuitously.

If the situation was real, I would probably discuss it with the CEO, but it would be after the decision to file was made and the paper trail was perfected. Then, I would point out our past practices and let him or her make the decision to mention or not mention the board member and note his or her status in the narrative.

Thank You both. We do typically list the principals etc. We have a SAR committee, and we were discussing possible scenarios. It makes for some spirited discussions... :-)