The FinCEN SAR Filing instructions state, "Complete a Part I section on each known subject involved in the suspicious activity. Persons who are victims of the suspicious activity are not subjects and should not be recorded in a Part I section. Victim information, if necessary for a complete description of the suspicious activity, should be recorded in Part V."
Edited to add: The exact title of the instructions is called "FinCEN Suspicious Activity Report (FinCEN SAR) Electronic Filing Requirements" with a release date of March 2015- Version 1.4. Found on page 88.
Last edited by Justin Case; 11/02/15 11:43 PM.
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CAMS