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#2118233 - 02/14/17 08:55 PM SAR Completion - Role in Transaction
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,338
Wisconsin
We don't file many SARs so I'm not sure of the correct box to check when it comes to the financial institutions role and the suspects role. I am filing due to structuring, so basically cash deposits coming in. Do I check "paying location" for the financial institution and "payee/receiver" for the subject's role? The SAR instructions aren't clear on this and don't provide any examples so I'm a little stumped.

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#2118242 - 02/14/17 09:32 PM Re: SAR Completion - Role in Transaction CSB98
CynthiaParker Offline
Junior Member
Joined: Apr 2006
Posts: 45
Midwest
If the subject is making cash deposits, then you would not complete the "selling location" or "paying location" fields in Part III, field 52 and you would not complete "payee/receiver" for the subjects role in Part I, field 25. Generally, those fields are completed when an item listed in Part II,field 40 is involved in the reported activity, such as "cashier's/bank checks," "money orders," "travelers checks," "government payment," or "personal/business checks." The fields for the subject may also apply if there were funds transfers involved in the activity, as they could be a sender or receiver.

If you access FinCEN's SAR FAQ's you can read clarifying instructions in question #18. https://www.fincen.gov/frequently-asked-questions-regarding-fincen-suspicious-activity-report-sar
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#2118244 - 02/14/17 09:38 PM Re: SAR Completion - Role in Transaction CSB98
CSB98 Offline
Diamond Poster
Joined: Dec 2003
Posts: 1,338
Wisconsin
Perfect! Thank you!

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