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#2204062 - 01/25/19 07:58 PM Cyber Event SAR
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
I have a question regarding the SAR Filing for a Cyber Event.
We have customers particularly elderly customers that fall victim to hackers who use the ruse they found a virus on their home personal computer and need to clean it up for a fee. Then, they get into the customer's computer and get their personal information including bank account info. Is this a reportable event requiring a SAR filing? Even if no loss has occurred?
Thank you!

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#2204084 - 01/25/19 09:43 PM Re: Cyber Event SAR Couples
TryingtoComply Offline
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Joined: Apr 2013
Posts: 1,882
The West
You have no obligation to file a SAR for something that happened to your customer. You need only be concerned with activity that is conducted at your bank.
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#2204115 - 01/28/19 03:45 PM Re: Cyber Event SAR Couples
Couples Offline
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Posts: 280
The Igloo
Even if they attempt to get access to our customers account?

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#2204116 - 01/28/19 03:48 PM Re: Cyber Event SAR Couples
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted By Couples
Even if they attempt to get access to our customers account?


has there been a transaction against the customer account by said fraudsters? because if you going to file a SAR every time someone attempts to gain access to your customer's information, you are going to be very busy writing...
Last edited by HappyGilmore; 01/28/19 03:50 PM.
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#2204120 - 01/28/19 04:07 PM Re: Cyber Event SAR Couples
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
Not yet! Most times, that we are aware of, the transactions are stopped or the customer becomes very suspicious and talks with someone at our branches.

And, you are correct! We would need a lot more personnel.

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#2204339 - 01/29/19 08:49 PM Re: Cyber Event SAR Couples
TryingtoComply Offline
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Joined: Apr 2013
Posts: 1,882
The West
When and if it happens, then yes. You are only responsible to report activity that occurs AT THE BANK, including attempts.
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#2204351 - 01/29/19 09:31 PM Re: Cyber Event SAR Couples
Couples Offline
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Joined: Apr 2009
Posts: 280
The Igloo
That makes sense but, you know FinCEN. Thanks

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#2205401 - 02/07/19 08:13 PM Re: Cyber Event SAR Couples
In It Together Offline
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Joined: Feb 2016
Posts: 16
If they attempted to use the bank as a conduit to commit fraud, even if they were not successful, the SAR rules require a SAR to be filed.

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