So we're debating as to what type of information needs to be inputted under the SAR "Describe where the activity occurred" section. My understanding is that this section should be limited to YOUR financial institution/branches where YOUR customer conducted suspicious activity. Others are insisting that ALL identifiable FIs, regardless if it involves your customer or not (as long as touched by YOUR customer's transactions), including address of domicile should be entered here. How are you addressing this matter, and where in the BSA/AML Examination Manual would I see a guidance clarifying this?

As I'm not sure about what type of activity you are talking about, I'll offer a general response to a general question. This comes from a 2003 FinCEN slide presentation:

Where did the suspicious activity take place?

* Identify the branch/department location or locations within the institution where the activity occurred (name of branch, office or department and the street address for each)

* Identify all account numbers & types of accounts affected by the transactions/activity

* Indicate if suspect transactions involve other domestic or international banks & identify the banks, their locations, account numbers, etc.


The slide show is out of date because it was not based on the FinCEN SAR. However this piece of advice is far more easily incorporated into the FinCEN SAR than it was in the legacy version.

[quote=Ken_Pegasus]As I'm not sure about what type of activity you are talking about

Where I am, the management insists on including all the counterparties (noncustomers who send/receive funds from our customer) as suspects. With that logic, does it make sense to include all the FI information/account numbers/address for these noncustomers? Pretty much, any parties that are "touched" by the customer's money are considered suspects, which I think, is a stretch.