There was an article found recently on a local website about one of our customers getting charged for Theft First Degree. She allegedly stole a large amount of money from a trust fund.

There was no suspicous activity on her accounts at our bank..that we can tell. Do we still file a SAR?

There was no suspicous activity on her accounts at our bank..that we can tell

Just document your review

When this issue has come up here (customer's name appears in the local paper being arrested for drugs, e.g.), we review the activity on the customer's account, and classify the customer as a "higher risk" subject to periodic reviews. Unless suspicious activity was "committed or attempted against the financial institution or involving a transaction or transactions conducted through the financial institution" as per SAR instructions, I would not file a SAR.

We recently had a similar case. Prior to the customer’s arrest, we were already questioning the source of wealth/funds. After the arrest, we filed a SAR.

The important thing to remember is that your SAR, if you file one, should be based on what you find in your bank's records, or activity that you observe. The arrest or indictment or arraignment of a customer may have led you to do (or update) your review, but it should not be, by itself, the trigger for the SAR.

A customer's press clippings regarding suspected or known involvement in illegal activity should trigger some enhanced due diligence. However, a requirement to file a SAR is determined by what you find in your records, not what you read in the newspaper.

Thank you everyone for your responses. We will document our review and continue to monitor the existing account for any suspicious activity.