Skip to content
BOL Conferences
Thread Options
#2131987 - 05/25/17 07:18 PM SAR completion question
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
John Doe owns ABC Inc. He structured deposits to the account so we will file a SAR.
Its been a while since we had to deal with entities rather than individuals for SAR filings.
For CTRS you have space for the entity and then the conductors.
We are not sure who the subject is. John Doe made the deposits. We thought it should be him, reference the account where the deposits were made and then in the narrative explain that Doe owns ABC Inc. However, we can also do the opposite, use the entity as the subject and then explain Doe's ownership of it and the fact that he made the deposits.
Help.

Return to Top
BSA/AML/CIP/OFAC Forum
#2131988 - 05/25/17 07:26 PM Re: SAR completion question Trees
BrianC Offline
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,721
Illinois
SAR's allow you to enter multiple subjects. Why not list them both as subjects and let law enforcement decide how to proceed?
_________________________
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!
www.tcaregs.com

Return to Top
#2131991 - 05/25/17 07:41 PM Re: SAR completion question Trees
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
That's what we do.

Return to Top
#2131998 - 05/25/17 07:59 PM Re: SAR completion question Trees
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
We also list the "conductor" and the entity if we have both.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2132011 - 05/25/17 08:46 PM Re: SAR completion question Trees
Trees Offline
Power Poster
Joined: Apr 2005
Posts: 4,013
Right! I forgot I had a dropdown for more subjects.
That works.
Thanks everyone.

Return to Top

Moderator:  Andy_Z