I am seeking any existing regulatory guidance or professional advice on a bit of a niche situation we're currently encountering. Need to remain anonymous given the sensitive nature of the issue.

We have encountered a combined fraud/identity theft situation where a bad actor was able to successfully pass off a forged ID at the teller window and complete a withdrawal large enough to merit a CTR filing. The specifics of the fraud are largely irrelevant to my question, suffice to say that due to a combination of factors, our BSA department filed a CTR listing the member as the conductor before they were notified of the fraudulent nature of the transaction.

This has left our BSA department in the position of (we assume) needing to amend the CTR to reflect that the withdrawal was completed by an unknown conductor. The amount of the withdrawal was enough to trigger a CTR filing, but is below the $25k minimum mandatory SAR filing threshold when an unknown conductor is involved.

We are stuck on determining the best course of action as it relates to CTR amendment/potential SAR filing, to ensure that this is both properly reported, and that we best protect ourselves (the institution). We have a couple of unanswered questions:

• Are we correct in our assumption that we must amend the CTR to reflect an unknown conductor for the withdrawal?

• Would there be any real benefit, other than corroborating the amended CTR with an unknown conductor, to filing a non-mandatory SAR when there is no identifying information of any kind for the subject that could be provided in the SAR?

• With regard to CTR filing (and potential SAR filing), how would you handle, or how have you handled, a similar situation at your institution?

Any help is appreciated!