Skip to content
BOL Conferences
Thread Options
#2078413 - 05/12/16 06:41 PM SAR on kiting
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
We have found that a customer is kiting. We have closed the account so no further kiting activity can occur. Do I still need to file a SAR since we have closed the account?

Return to Top
BSA/AML/CIP/OFAC Forum
#2078417 - 05/12/16 06:46 PM Re: SAR on kiting dg
edAudit Offline
Power Poster
edAudit
Joined: Jul 2008
Posts: 4,796
You are here
if the dollar threshold has been breached a SAR is necessary even if the bank has lost no money.
_________________________
Opinions can be considered as coming from anywhere but my employer.

CAMS


Return to Top
#2078418 - 05/12/16 06:48 PM Re: SAR on kiting dg
Bec Offline
Diamond Poster
Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Also consider that if it is addressed in your BSA/AML policy that you will file a SAR if kiting is detected, then you need to file as well.
_________________________
Go Packers

Return to Top
#2078419 - 05/12/16 06:49 PM Re: SAR on kiting dg
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If the amount involved exceeded $5,000, yes. The issue will be how to calculate the amount involved.
_________________________
In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.

Return to Top
#2078452 - 05/12/16 08:02 PM Re: SAR on kiting dg
dg Offline
Platinum Poster
Joined: Jan 2005
Posts: 811
Pacific NW
What is the best way to calculate the amount when researching the activity, such as how far back, should our research include?

Return to Top
#2078458 - 05/12/16 08:18 PM Re: SAR on kiting dg
Big Dog Offline
Power Poster
Big Dog
Joined: Mar 2005
Posts: 2,659
Kennel
Ken provided a link above to a discussion regarding how to calculate. Much depends on your procedures so make sure you are consistent in your application of the calculation. There is no guidance on how far back you go. if your program dictates a time period, use that as a starting point. If it is determined that the activity started before, feel free to go back and get it all. Be prepared to explain to regulators any situations where the activity went on for an extended period of time without being identified. Document any new systems, reviews or processes that may have identified the activity at this point and prompted the review going back.
_________________________
CAMS, AMLP, AKC, K-9






Return to Top

Moderator:  Andy_Z