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#2123073 - 03/22/17 03:05 PM Does this warrant a SAR?
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
We have a customer and non-customer that applied for a mortgage. The non-customer does not have any form of identification. He does not have a TIN either. He stated he had income from a local farm that he works at but does not have a work visa. I can see where this is heading but do you think it warrants a SAR filing?
Thank you!!

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#2123077 - 03/22/17 03:11 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
Daisy Doodle Offline
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Posts: 1,030
Southern U.S.
He didn't lie to you, or put fraudulent info on the application. What would be your basis for filing?

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#2123081 - 03/22/17 03:18 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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He did not have a SSN or work visa but is collecting a paycheck. Possibly (probably) an undocumented immigrant. I'm just wondering if it's really up to FI's to report this type of thing if we are suspicious of it.
Last edited by ComplianceGurl; 03/22/17 03:19 PM.
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#2123082 - 03/22/17 03:18 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
RockChucker, CAMS Offline
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The Country
Based only on the information you provided I don't see where filing a SAR is necessary. The course of action you might take is to decline the mortgage application.
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#2123085 - 03/22/17 03:21 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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RockChucker-We did deny the loan but I'm just concerned we might get criticized by our regulator for not reporting it.

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#2123091 - 03/22/17 03:33 PM Re: Does this warrant a SAR? RockChucker, CAMS
Elwood P. Dowd Offline
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Posts: 21,939
Next to Harvey
Okay, if you had to file a SAR, think about what the narrative would say: "Based solely on his statements, we believe this person is working illegally in the U.S." I can't think of what the next sentence would be other than to acknowledge that it's a defensive filing.
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#2123102 - 03/22/17 03:56 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
ComplianceGurl, CRCM Offline
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Joined: Jul 2007
Posts: 498
Thank you all! I guess I was overthinking it. Time for a vacation!

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#2123107 - 03/22/17 04:08 PM Re: Does this warrant a SAR? ComplianceGurl, CRCM
edAudit Offline
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edAudit
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You are here
I will take the opposite conclusion based upon and recent non related exam "findings"

â—¦May involve potential money laundering or other illegal activity (e.g., terrorism financing).

https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_015.htm
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#2123223 - 03/23/17 12:21 PM Re: Does this warrant a SAR? edAudit
ComplianceGurl, CRCM Offline
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Thank you edAudit for your feedback!

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