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#1943888 - 07/21/14 10:02 PM refusal to provide info/file SAR issue
Trees Offline
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Joined: Apr 2005
Posts: 4,013
We know that a refulsal to provide key personal info is a reason to file a SAR, and we will in all instances where the amount of the trans. meeting reporting requirements.

We currently use a manual log to obtain info on cases where a non-customer is getting $3,000 or more in cash. These are usually people getting card cash advances, currency exchange or non-customers cashing an on-us check. In a few cases, it is the customer but that is OK as we have the details anyways.

In the cases of a non-customer who refuse to provide the info and the amount is, for example, $3500, would you file the SAR, even though it is below the minimum amount?

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#1943921 - 07/22/14 12:31 PM Re: refusal to provide info/file SAR issue Trees
DeeQ Offline
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Joined: Dec 2002
Posts: 40,765
Turnpike Exit 10
Decline the transaction and move on.
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#1943934 - 07/22/14 12:41 PM Re: refusal to provide info/file SAR issue Trees
JacF Offline

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Joined: Nov 2001
Posts: 6,719
PA
DeeQ has given you the best advice- decline the transaction if the conductor will not cooperate with your ID standards.

That said, in answer to your question, I would not file in the example you describe, since there is no attempt to avoid any reporting or recordkeeping required by BSA.

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#1944317 - 07/22/14 08:33 PM Re: refusal to provide info/file SAR issue Trees
J2C Offline
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Joined: May 2004
Posts: 1,475
Big Brother knows and that's a...
Why would you perform a transaction for a non-customer that is refusing to comply with your policy and procedure? Decline the transaction and move on. I would also alert the staff in the event the non-customer attempts the transaction at another branch.

He should try doing the transaction at an MSB-- may have better success.

Last edited by jennyfromthebloc; 07/22/14 08:33 PM.
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#1944332 - 07/22/14 08:50 PM Re: refusal to provide info/file SAR issue Trees
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,192
New York City
I'm going to join the chorus of "decline and move on."
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#1944369 - 07/22/14 09:30 PM Re: refusal to provide info/file SAR issue Trees
Sunshine Lady Offline
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Joined: Apr 2014
Posts: 629
I agree. Tell the customer that you cannot help them if they are not willing to help you in providing the information you need and suggest alternative options.
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#1944712 - 07/23/14 06:13 PM Re: refusal to provide info/file SAR issue Trees
NE Wx Forecast - Frosty Offline
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NE Wx Forecast - Frosty
Joined: Mar 2011
Posts: 442
SE, Nebraska
Trees, with all due respect and no insult intended, this indicates that your bank does not know the difference between the law and bank procedure. You need to do some educating at your bank.
Let's say it was $11,000 non customer and they refuse to provide their SSN (for the CTR). They are fully within their rights to tell you to blow chow, and some other choice words. But that is not against the law. The teller should explain the law, let them decide and if they still refuse, show 'em the door. No SAR. It's only when the law is actually being circumvented in some way that things get interesting.

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#1944949 - 07/23/14 10:16 PM Re: refusal to provide info/file SAR issue Trees
TryingtoComply Online
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Joined: Apr 2013
Posts: 1,965
The West
"Let's say it was $11,000 non customer and they refuse to provide their SSN (for the CTR). "


29 b on SAR - Customer cancels transaction to avoid BSA reporting and recordkeeping requirements.
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#1945028 - 07/24/14 01:51 PM Re: refusal to provide info/file SAR issue Trees
edAudit Offline
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edAudit
Joined: Jul 2008
Posts: 4,781
You are here
Agree with TryingtoComply

File away
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#1945071 - 07/24/14 02:25 PM Re: refusal to provide info/file SAR issue Trees
BSA Smitten Offline
Junior Member
Joined: Jul 2013
Posts: 41
Great Lakes
I second that motion (Trying & Ed)
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