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#1735982 - 08/28/12 08:22 PM New SAR due to new account?
Lafalot Offline
Junior Member
Joined: Apr 2012
Posts: 40
We filed a SAR on a customer for attempted structuring and refusing to complete a transaction after CTR information was requested. Now they have attempted to do the same thing again only through their children's accounts. Should we file a NEW SAR (I'm thinking...yes) or do another one as a follow-up to the original (we are still within our 90 days)?

I appreciate your assistance.

Thanks, Lisa

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#1735985 - 08/28/12 08:26 PM Re: New SAR due to new account? Lafalot
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
Since the situation involves the same suspect, I would document on the 90-day SAR documenting the new information.
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#1735986 - 08/28/12 08:28 PM Re: New SAR due to new account? Lafalot
John Burnett Offline
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John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Same suspects, same behavior, different accounts. I'd say this is a follow-up SAR if 90 days have not yet passed since the first filing. Just make sure to add the new accounts. That they are attempting this through the kids' accounts makes it clear to me they are deliberately structuring.
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#1735987 - 08/28/12 08:28 PM Re: New SAR due to new account? Lafalot
Dani York, CRCM Offline
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Dani York, CRCM
Joined: Apr 2005
Posts: 3,663
TN
Ditto Brenda. SARs follow subjects, though you should definitely point out the change in activity (account usage, etc) in the narrative.
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#1735991 - 08/28/12 08:33 PM Re: New SAR due to new account? Lafalot
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
In addition to the SAR you might also consider closing all accounts of these family members.

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#1736031 - 08/28/12 10:13 PM Re: New SAR due to new account? devsfan
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
In addition to the SAR you might also consider closing all accounts of these family members.


Ditto.

Few consumer customers provide a net return to the bank sufficient to pay for the time & trouble involved in SAR filing. Show them the gate.
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#1736196 - 08/29/12 03:21 PM Re: New SAR due to new account? Lafalot
Lafalot Offline
Junior Member
Joined: Apr 2012
Posts: 40
Thanks to all!!!

Lisa

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