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#2047660 - 11/02/15 11:17 PM Use the victim's name as the subject of a SAR?
gcg Offline
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Joined: Mar 2007
Posts: 126
The examiner is telling me that when our customer has been the victim of a scam and we don't know who perpetrated the crime, we should use the victim's name as the subject of the SAR and not use 'Unknown'.

I don't think this is right. Can someone tell me where to find that in writing so I can show the examiner?

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#2047661 - 11/02/15 11:40 PM Re: Use the victim's name as the subject of a SAR? gcg
Buddy the Elf Offline
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Buddy the Elf
Joined: May 2002
Posts: 975
first lily pad on the right
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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#2047689 - 11/03/15 02:27 PM Re: Use the victim's name as the subject of a SAR? gcg
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
As referenced by Justin, the victim of a scam should not be referenced as the subject of the SAR filing. You may include them in the narrative along with the details of the scam.
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#2047704 - 11/03/15 03:00 PM Re: Use the victim's name as the subject of a SAR? gcg
gcg Offline
100 Club
Joined: Mar 2007
Posts: 126
Thanks bunches !!!!!

I knew someone on BOL would know. I can always count on you guys!

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