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#2015204 - 05/20/15 04:33 PM SAR Transaction Amount
complylady Offline
Platinum Poster
Joined: Jul 2002
Posts: 614
When completing the SAR transaction amount, do you include the entire transaction or only the part of the transaction that is suspicious? For example, someone deposits checks totaling $10,000 and cash in the amount of $9,900. Do you put $19,900 for the transaction amount or $9,900 for the amount that appears to be structuring? I cannot locate a clear definition. Thanks.

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#2015209 - 05/20/15 04:46 PM Re: SAR Transaction Amount complylady
Matt_B Offline
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Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
You would report whatever part you considered suspicious. Based on your example, only the cash sounds suspicious, unless there is some pattern of odd activity with the checks as well and someone thinks checks fall under the same guidelines as cash.

But still at the end of the day, you're reporting suspicious activity, no reason to include the rest in your total, and if anything I'd only include it in the narrative if it seemed at all relevant.
Someone's about to get horned!

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#2015271 - 05/20/15 07:29 PM Re: SAR Transaction Amount complylady
NotDoneYet Offline
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Joined: Jul 2010
Posts: 482
I agree with Matt B.

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#2015471 - 05/21/15 04:35 PM Re: SAR Transaction Amount complylady
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
I also agree with Matt B.

Further, here's an example of when I might consider the check activity to also be suspicious: The checks are money orders or cashier's checks, or are sequentially numbered checks. (Potential indicators that the customer may have traded cash for those check items somewhere else, and is layering them along with the addidional $9,900 he's presenting to me.)

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#2015841 - 05/22/15 09:18 PM Re: SAR Transaction Amount kw004h
Cape Codder Offline
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Joined: Jul 2011
Posts: 413
Or are obvious payments received from clients of the corporate business being deposited to the personal account of the sole principal of the corporation . . .
Nothing difficult is ever easy.

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