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#2109516 - 12/02/16 08:16 PM SAR Stupid question
GrannieTwo Offline
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Joined: Nov 2010
Posts: 180
Central IL
Regarding SARs, does LE strictly mean local, county, state, federal police agencies or does it include any governmental agency that you contact for additional help such as for Elder Abuse? I have listed this Elder Abuse agency information in the narrative of the SAR but am stuck at the LE. Opinions? Anyone? Sorry I told you it was stupid.
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#2109517 - 12/02/16 08:31 PM Re: SAR Stupid question GrannieTwo
bcompliance Offline
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I have always understood it to be Law Enforcement Agencies (ex. police, sheriff, FBI) and not a person at the local job and family services who handles elder abuse cases.
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#2109519 - 12/02/16 08:34 PM Re: SAR Stupid question GrannieTwo
Daisy Doodle Offline
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Southern U.S.
At my last bank, Adult Protective Services was a division of the county prosecutors office. That is pretty 'LE adjacent'.

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#2109523 - 12/02/16 08:45 PM Re: SAR Stupid question GrannieTwo
McFly Offline
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This seems like it could be interpreted either way.
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#2109536 - 12/02/16 09:40 PM Re: SAR Stupid question GrannieTwo
RockChucker, CAMS Offline
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The Country
I think you would be ok to include it in this case. As far as I understand it is to allow those who use the SARs to contact the individuals you contacted to help eliminate duplication of investigation etc...
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#2109574 - 12/03/16 02:36 PM Re: SAR Stupid question GrannieTwo
Elwood P. Dowd Offline
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Next to Harvey
Footnote 73 of the FFIEC Examination Manual (2010) gives a good "starter" list of law enforcement agencies.

Examples of agencies to which a SAR or the information contained therein could be provided include: the criminal investigative services of the armed forces; the Bureau of Alcohol, Tobacco, and Firearms; an attorney general, district attorney, or state’s attorney at the state or local level; the Drug Enforcement Administration; the Federal Bureau of Investigation; the Internal Revenue Service or tax enforcement agencies at the state level; the Office of Foreign Assets Control; a state or local police department; a United States Attorney’s Office; Immigration and Customs Enforcement; the U.S. Postal Inspection Service; and the U.S. Secret Service. For additional information, refer to Bank Secrecy Act Advisory Group, “Section 5—Issues and Guidance,” The SAR Activity Review—Trends, Tips & Issues, Issue 9, October 2005, page 44 at www.fincen.gov.

My practical test would be if they can arrest someone; i.e. they have police powers, then they are law enforcement. Otherwise they are not. The role of a state's "adult protective services" department varies from one state to the next.

The answer is specific to your state. Daisy offers a good example, but it would not be true in my home state.
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#2109597 - 12/05/16 01:50 PM Re: SAR Stupid question GrannieTwo
GrannieTwo Offline
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Joined: Nov 2010
Posts: 180
Central IL
Thank you all. I had called FinCEN and received a message back. I was told that LE does stand for Law Enforcement which would go in 92-95 and if not an LE, in the narrative. The instructions do not specify what is an LE. Not exactly the help I thought I'd get so I'm so glad I went to BOL. Looking at the SAR Activity from 2005, the additional info I read was if the supervisory agency has authority under federal and state law. I will find out for sure but my guess is no. If that is the case, I'm going to remove it from LE and leave it in the narrative. Thanks again for all the help.
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