Reviving a dead post, because this is our current nightmare. I called FinCEN about the account numbers, because the data thieves got card data and PINS, and cash at other places. Still unknown subjects. I called FinCEN, because the thieves got card numbers, not account numbers. FinCEN rep held that because the activity occurred through the accounts, even though the subjects don't have the account numbers and didn't have control over the accounts, they had control of the linked cards. So, I will have to put all my affected customers' account numbers into item 24.
Last edited by Always In Training; 02/22/17 06:18 PM.
Edited to add: I'm reviving in case someone else searches for info about ATM skimming SAR reports. There isn't a lot of guidance out there as to what should or shouldn't be on the form.