I want to post a hypathetical scenario with the new SAR form that I'm sure will be a true scenario to all in the near future. The question is around Account Numbers Affected.

The new FinCEN form reads that you list the account number(s) affected that are related to subject. What do you do when the account number affected is not related to any subject? Do you only list the affected account number in the narrative section?

I'm not sure that the specific question is answered in any of the reference materials.

However, I'd be wondering why a non-subject account number is being reported. So I would include as much information as to why the account is part of the narrative and yet not related to a subject (as well as who owns the account, etc.).

Do you have a specific scenario in mind? It might help generate more of a discussion.

Let's say the hypathetical scenario is suspected elder exploitation. I'm a caregiver, I've convinced my elderly employer to sign blank checks, I fill out the amount and cash them. The elderly employer is considered a victim and the caregiver the subject. Since the caregiver is not a signer on the account involved in the unusual activity, would you then just list the involved account number in the narrative as opposed to listing it in the subject section?

There is no requirement that the account number listed be that of the suspects. If the SAR involves checks from other people and other banks, even those would be listed with the proper TIN of the financial instutition on which they are drawn.

So rlcarey, are you saying that if I bring checks for $9,000 in from Bank A and cash them at Bank B (your bank), you are going to list Bank A's TIN and the account # on the checks in that field?? The field reads "account numbers affected that are related to subject". What if they are not drawn on the subjects account at Bank A? I guess it's up to our individual interpretation of the word 'related'?

I did just find a definition from FinCEN on 'related': "An account is related to a subject if the subject owns the account, has control over the account, or conducted activity in or through an account the subject does not own or control"

I would still like others' opinion/guidance on if I'm interpreting this field correctly. I'm reading that if I send suspicious wires from my account at Bank A to Bank B (my bank), I'm listing both account numbers in that field?

conducted activity in or through an account the subject does not own or control

I think that pretty much says it all. Any bank and account number that you can identify involved in the suspicious activity needs to be included up to 99 accounts.

I agree with Randy. Also, note that in the magic box that appears when you hover over the account number field, the instructions tell you to list the suspect's relationship to the affected account in Part V and gives an example of suspect "used stolen credit card xxx". So in your wire example, you would list both accounts associated with the wire (the to and from accounts) and in your narrative explain that the subject was either the sender or the beneficiary, or whatever other relationshiop they had to the accounts. For your elder exploitation example, you would list the elder's account number, but in your narrative explain that the account belonged to the victim and the suspect swindled the elder, etc.