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#2123263 - 03/23/17 02:49 PM SAR Filing Question
Sherri B Offline
New Poster
Joined: Apr 2016
Posts: 3
Question on an SAR I'm trying to complete. I have an elder exploitation case involving wire fraud. I'm listing all the individuals that received money from the elderly man as suspect as I know we cant include the elderly man as a suspect but reference him in the narrative. I just had new information brought to me regarding this case that should be included on this SAR, but I would have to include him as a suspect. He took out cash (also structured) for what I believe to bring to another bank to wire out more money as he doesn't think he's being scammed. Would I include him as a suspect in the elder abuse SAR and detail in the narrative my reason behind it, or file a new SAR, and reference the elder abuse SAR in the new SAR with the cash activity? Sorry if this is confusing! Any insight you have would be much appreciated.

Thanks!

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#2123279 - 03/23/17 03:20 PM Re: SAR Filing Question Sherri B
Midwest BSA Offline
Member
Joined: Sep 2014
Posts: 54
Yuck. If it were me, I'd probably just do 1 SAR since it's all tied together. List him as a subject, but be sure to explain your reasoning in the narrative. That's most likely the cleanest way to do it.

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#2123291 - 03/23/17 04:04 PM Re: SAR Filing Question Sherri B
bcompliance Offline
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Joined: Sep 2014
Posts: 1,246
I agree with 1 SAR. Did the people who are taking advantage of him advise him to structure the funds from the other bank? That may also play a part in the subject vs. narrative scenario.
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#2123315 - 03/23/17 05:58 PM Re: SAR Filing Question Sherri B
RockChucker, CAMS Offline
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Joined: Jul 2013
Posts: 1,658
The Country
Agree, 1 SAR should be sufficient and just make sure your narrative covers all the details.

Good luck.
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A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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