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#2182163 - 06/18/18 07:33 PM SAR-New Activity during investigation
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
I have a situation in the business which is the subject of a SAR that I am filing for structuring has had some check fraud. I am just wondering, would anyone include the check fraud situation?
My thought is that I will indicate that the checking account in which the alleged structured occurred from was closed due to possible check fraud and a new checking account was established in its place and something to the effect that the new account will be monitored for ongoing activity.
I see three options here:
Leave it mentioned briefly as indicated above?
Go into detail regarding the possible check fraud?
not mention the possible check fraud altogether?
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#2182167 - 06/18/18 07:38 PM Re: SAR-New Activity during investigation Bec
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,801
Galveston, TX
a new checking account was established in its place - first mistake smile

If the check fraud crossed the mandatory reporting threshold, you have no choice but to file on it. Otherwise at this point, I think it is irrelevant if it is not related.
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#2182170 - 06/18/18 07:47 PM Re: SAR-New Activity during investigation Bec
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,767
Illinois
Did your customer commit the check fraud or is your customer the victim?

If the former, then include both on the same SAR if the check fraud crossed the threshold.

If the latter, you are filing on two separate instances of suspicious activity. 1. Your customer whom your suspect of structuring. 2. The unknown party that committed fraud against your customers. If the threshold is met, you'd have two SARs to file.
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#2182176 - 06/18/18 08:01 PM Re: SAR-New Activity during investigation Bec
Bec Offline
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Bec
Joined: Jul 2010
Posts: 1,115
The Great White North
Thank you both for your quick and insightful responses. Definitely helpful!
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