Was curious as to what the proper guidence in this scenario might be.

My understanding has been that when one individual from a joint account is conducting strucutred cash withdrawals both individuals need to be listed on the SAR form. Reason being is that even though the other individual did not conduct any of the transactions, their name is still on the account and therefore are still responsible for the transactions that go through it.

Does that sound correct? If so, that would mean that the two or more individuals box needs to marked as well right?

Thanks for the feedback.

I would not say that both 'need' to be shown as suspects on the SAR but that is how we do it. If the transactions are conducted by only 1 of them we indicate that information in the Narrative.

I would mention in the narrative that it is a joint account along with names of account owners, but also make clear which one was suspected of conducting the structured cash withdrawals and signing the withdrawal slips.

This is pretty much how we handle it. We would only list the person who actually conducted the structured transactions as a SAR subject, but we would note in the narrative that it's a joint account. We would put the joint owner's name in the narrative and state that the joint owner was not a subject because he/she did not structure any transactions.

I suggest you list both owners as "subjects" and explain in the narrative who the active party is.

That's not an announcement of how to do it "right," it's simply the method where the bank gives law enforcement the most information about all the parties involved and where you do not have to listen to a reviewer say you should have included all parties to the account because they knew or should have known about the activity...

That's interesting, Ken. I've always tried to be accurate and only list as subjects those parties that we believe participated in the suspicious activity. I figured law enforcement was getting the information in the narrative, too, so never thought of including as subjects parties that we didn't really consider to have done anything suspicious.

I'll readily concede your point...

Over the years I've just gravitated to completing the reports with the maximum amount of information. If I'd filed a report months before listing only the active party as the subject and had to listen to a teenaged examiner say, "Well how do you know, maybe she's structuring the transactions that way because her husband told her to do so!" I probably wouldn't be polite.

It's just a personal decision on may part, somewhat buttressed by the fact they are now called "subjects" not "suspects;" i.e. either or both parties could be the decision maker and I have no way to sort them out.