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#2033504 - 08/13/15 02:53 PM SAR and subject address-urgent!
Trees Offline
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Joined: Apr 2005
Posts: 4,013
Subject is a foreign student. Do we use their US, school address or home address?

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BSA/AML/CIP/OFAC Forum
#2033522 - 08/13/15 03:19 PM Re: SAR and subject address-urgent! Trees
Daisy Doodle Offline
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Joined: Feb 2014
Posts: 1,030
Southern U.S.
Here's what I think.

When you opened the account you would have obtained their current physical address, which presumably would be their school address. I would use that. You will have their passport as CIP presumably with the identifying numbers. Law enforcement would be easily able to find their foreign address, or you could include it in your narrative.

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#2033523 - 08/13/15 03:20 PM Re: SAR and subject address-urgent! Trees
TXBSA Offline
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Joined: May 2006
Posts: 170
TX
The address field is expandable. You should put all known addresses you have.

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#2033539 - 08/13/15 03:37 PM Re: SAR and subject address-urgent! Trees
Trees Offline
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OK, folks. I am going with the school but include also in the narrative.

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#2033559 - 08/13/15 04:34 PM Re: SAR and subject address-urgent! Trees
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
What TXBSA stated is the correct way of doing it.
You must include all known addresses on the form.
The form has a + sign to enable you to enter multiple addresses.

Same applies to phone numbers.

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#2055133 - 12/21/15 03:20 PM Re: SAR and subject address-urgent! Trees
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 809
NY
I agree with TXBSA and MagicCity since the FinCEN instructions say to enter multiple addresses on the subject page.

However, interestingly, a FinCEN representative (recently) said (of course only verbally, not in writing) not to include multiple addresses on the subject page, but rather, in the narrative, if deemed pertinent. Why do FinCEN reps give advice contradictory to the written instructions?
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#2055144 - 12/21/15 04:25 PM Re: SAR and subject address-urgent! happyauditor
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Quote:
Why do FinCEN reps give advice contradictory to the written instructions?


My experience is that they only do that when 1) they have not read the instructions and 2) have no personal familiarity with the report at all.

Include all current addresses you have; residence, P.O. Box, the lake house, etc. using the (+) thingie. Ambiguity exists regarding "previous" addresses: I vote "No." Putting anything into the narrative instead of a "text box" that requests that information makes it harder for law enforcement to find and link to reports listing the same information.

As for a non U.S. person, if they signed a W8-BEN or its equivalent, gave you a U.S. address and a non U.S. address. Report both.
Last edited by Ken_Pegasus; 12/21/15 04:38 PM. Reason: Add last paragraph
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#2055147 - 12/21/15 04:31 PM Re: SAR and subject address-urgent! Trees
happyauditor Offline
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happyauditor
Joined: Nov 2004
Posts: 809
NY
Thanks Ken. It is things such as this that make my life harder as an auditor...sometimes I feel like I am either in the twighlight zone or on candid camera. smile
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