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#2165057 - 02/16/18 08:36 PM SAR IOLTA
Sunpokey Offline
Junior Member
Joined: Nov 2015
Posts: 28
If we have an IOLTA account that we are filing a SAR on, would the Law office be a subject, if the activity being filed on was for a
client and had nothing to do with the business itself?

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#2165062 - 02/16/18 08:44 PM Re: SAR IOLTA Sunpokey
BrianC Offline
Power Poster
Joined: Nov 2004
Posts: 6,501
If the law office is not involved in the suspicious activity, it is not a subject. It may be appropriate to list the law office in the narrative if it helps to tell the story of what you suspect. No different than not including a scam victim as a subject even if the transactions passed through their account.
Last edited by BrianC; 02/16/18 10:30 PM. Reason: clarification
Sola Gratia, Sola Fides, Sola Scriptura, Solus Christus, Soli Deo Gloria!

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#2165064 - 02/16/18 08:50 PM Re: SAR IOLTA Sunpokey
Sunpokey Offline
Junior Member
Joined: Nov 2015
Posts: 28
If the client the law office is representing has given them cash derived from illegal activity who is the subject of the SAR?

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#2165077 - 02/16/18 09:33 PM Re: SAR IOLTA Sunpokey
80's Lady Offline
Gold Star
Joined: Apr 2007
Posts: 295
The client. If the law office is aware and complicit, they would also be a subject (i.e. assisting them with laundering the funds).
I use to think I was a smart cookie before I started working in Compliance. Now, I have mastered the art of the blank stare!

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#2165155 - 02/20/18 03:29 PM Re: SAR IOLTA Sunpokey
MollyM Offline
100 Club
Joined: Jul 2005
Posts: 112
If you know that the law office was aware of and complicit with the activity in question, then, yes, you definitely include the attorney/law office.
“The strongest of all warriors are these two—Time and Patience.”
Leo Tolstoy
Russian Author

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