Thread Options
#1833542 - 07/17/13 01:30 PM SAR for ATM Skimming Device
Kristen C. Offline
Junior Member
Joined: Jan 2008
Posts: 30
One of our ATMs had a skimming device attached to it last Friday. A customer noticed it when he went to use the ATM, he pulled it off of the machine and notified the police and our bank right away. The police came and took the device. We were able to view the camera footage and could see two men attaching the device to the machine about 2 hours before our customer used it. Our Operations department blocked the debit cards that had been used during that time frame and no accounts suffered losses. Lucky for us it was a rainy day and not many folks were using that ATM.

My question is since there was no loss at all do I need to file a SAR?

Return to Top
BSA/AML/CIP/OFAC Forum
#1833548 - 07/17/13 01:56 PM Re: SAR for ATM Skimming Device Kristen C.
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Can you identify any specific amount of money involved in the attempt? Can you identify either of the men you have on camera?

Whether your bank suffered a loss does not determine whether a filing is required.
_________________________
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
#1833887 - 07/18/13 12:31 AM Re: SAR for ATM Skimming Device Kristen C.
BetsyS Offline
Gold Star
Joined: Jun 2009
Posts: 468
What about non-customer cardholders using the ATM? If there were any, have you notified their issuers?
Last edited by BetsyS; 07/18/13 12:32 AM.
_________________________
Let's start at the very beginning; A very good place to start...

Return to Top
#1834164 - 07/18/13 04:16 PM Re: SAR for ATM Skimming Device Elwood P. Dowd
Kristen C. Offline
Junior Member
Joined: Jan 2008
Posts: 30
We cannot identify either of the men, no money was taken by them. Luckily it was a rainy night and there were only a few transactions done when the device was attached. The cards that were our customers were blocked immediatley and none lost any money. There were a handful of other bank customers involved and we notified those banks. As far as I know no customers had any transactions posted to their accounts. The device was not a wireless one so when our customer removed the skimmer and turned it over to the police it still had the info on it.

Return to Top
#1834260 - 07/18/13 06:56 PM Re: SAR for ATM Skimming Device Kristen C.
John Burnett Online
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,289
Cape Cod
I'd say that filing a SAR in these circumstances would be optional. You can't identify the perps; you could indicate in the narrative that you have video, but don't recognize the bad guys. I think its usefulness to law enforcement would be minimal.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1834369 - 07/18/13 09:04 PM Re: SAR for ATM Skimming Device Kristen C.
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
Also, since the police are aware of the situation (probably before the bank was) and have the device there is no benefit or need to file a SAR.

Return to Top
#1835537 - 07/23/13 04:11 PM Re: SAR for ATM Skimming Device Kristen C.
Indy Banker Offline
Platinum Poster
Joined: Aug 2010
Posts: 528
I agree, this sounds like a matter for state or local law enforcement to investigate. I can't imagine FinCEN/IRS investigators being interested. It can't hurt to file, but we would most likely not file with the situation you describe.

Return to Top
#2039382 - 09/18/15 04:30 PM Re: SAR for ATM Skimming Device Kristen C.
ComplianceBanker Offline
New Poster
Joined: Oct 2014
Posts: 12
Follow up from a topic a while ago, but say a bank were to file a SAR for the skimming of more than 99 of debit cards with an unknown subject. What would the expectation be with regards to completing item 24? Would we be expected to input 99 accounts associated with the cards? Seems like law enforcement would only be interested knowing that a skimming incident had occurred but since we know the accounts involved perhaps we should be including account numbers.

Return to Top
#2039388 - 09/18/15 04:36 PM Re: SAR for ATM Skimming Device ComplianceBanker
Elwood P. Dowd Offline
10K Club
Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
If you believe filing a SAR is required, you need to provide all the information you have.
_________________________
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
#2039406 - 09/18/15 04:53 PM Re: SAR for ATM Skimming Device Kristen C.
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
You could attach the numbers as a file to your SAR.

Return to Top
#2039452 - 09/18/15 06:22 PM Re: SAR for ATM Skimming Device Kristen C.
Beachbum, CRCM Offline
Gold Star
Joined: Dec 2006
Posts: 479
Knee Deep in Regs
Agreed. With that many numbers, I would attach a file.
_________________________
What we think, we become.
Buddha

Return to Top
#2039477 - 09/18/15 07:12 PM Re: SAR for ATM Skimming Device Kristen C.
John Burnett Online
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,289
Cape Cod
Absolutely. These accounts aren't the subject of your report, after all. They are just where the transactions ended up.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#2119126 - 02/22/17 06:13 PM Re: SAR for ATM Skimming Device Kristen C.
Always In Training Offline
Diamond Poster
Joined: Jul 2006
Posts: 1,108
Where the Green Grass Grows
Reviving a dead post, because this is our current nightmare. I called FinCEN about the account numbers, because the data thieves got card data and PINS, and cash at other places. Still unknown subjects. I called FinCEN, because the thieves got card numbers, not account numbers. FinCEN rep held that because the activity occurred through the accounts, even though the subjects don't have the account numbers and didn't have control over the accounts, they had control of the linked cards. So, I will have to put all my affected customers' account numbers into item 24.

Edited to add: I'm reviving in case someone else searches for info about ATM skimming SAR reports. There isn't a lot of guidance out there as to what should or shouldn't be on the form.
Last edited by Always In Training; 02/22/17 06:18 PM.
Return to Top
#2119172 - 02/22/17 09:37 PM Re: SAR for ATM Skimming Device Kristen C.
NBT Offline
New Poster
Joined: Feb 2017
Posts: 11
We recently filed an ATM skimming SAR for many affected accounts and did not add the account numbers into item 24. The account numbers were provided in the transaction details tab that we use in BAM (banker's toolbox). So ultimately they were submitted.

Return to Top

Moderator:  Andy_Z