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#1997792 - 02/24/15 03:52 PM How does your institution use this SAT type?
AMLMGR Offline
Junior Member
Joined: Jan 2010
Posts: 35
I'm curious as to how other institutions use the SAT type "Two or more individuals working together"? Do you check this when you have two unrelated individuals working together or two accounts involved as opposed to two signers on one account? Thanks!

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#1997826 - 02/24/15 05:14 PM Re: How does your institution use this SAT type? AMLMGR
PrimeTime Offline
100 Club
Joined: Nov 2014
Posts: 173
To me, the statement "two or more individuals working together" means that it's a collaborative effort in order to conduct the suspicious activity.

For example, my institution checked off that box in a scenario in which two or more individuals were being used to structure cash out of an account. In this particular scenario, 2 of the individuals were signers, and 1 was not, although I don't believe that would have made a difference, as regardless of their relationship to the account they were still working together.

I don't have it in front of me currently, but it's always helpful to hover over the box in question on the e-filing site, as it brings up additional information, although sometimes that does lead to further confusion!
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