Received conflicting information on completing SAR Item 24 - Financial inst. EIN and acct. numbers affected. Are we to include FI EIN/Accounts numbers for all activity involved? We have a customer we are filing a SAR on who deposited several checks from several different individuals. The customer did not write the checks, only deposited them into their account. Are we to include the bank information from each check the customer deposited into their account? Similar if a customer received an unusual wire from a different FI, would we include the bank information from the wire if it wasn't from the subject's account?

From the SAR instructions: [i]"An account is related to a subject if the subject owns the account, has control over the account, or conducted activity in or through an account the subject does not own or control."[i]

The "conducted activity in or through an account the subject does not own or control." portion is what I believe is causing the confusion.

In my opinion, I would only include the account number affected at your FI where the checks were deposited to. In my experience I have never included the account numbers of where the checks are drawn from. You can include this part in the narrative to explain so and so received a check totaling $$ drawn from the XX account at Bank of Wherever (routing #, account#).
Hope this helps!

We do what SmallBank suggested.

Only report account numbers at your institution and use the narrative or attachment for others.

What about in a kiting scenario, would you list the account number the customer is using at the other FI?

I'd report that in the narrative as well or CSV attachment if there were enough transactions.

To follow up on this, would we list the official check account number if the suspect used one of our official checks to conduct the suspicious activity?

I would

Thanks! I'm also working on a SAR now where we have a non-customer (subject) who is cashing on-us checks payable to him. We would list the on-us account number in Item 27, correct? Reading the SAR instructions, it says "An account is related to a subject if the subject owns the account, has control over the account, or conducted activity in or through an account the subject does not own or control." So I would think I would enter that on-us account number as being related to him since activity is being conducted through the account. (Sorry, started a new job and things are being done differently here than at my previous bank and it's really creating a lot of headaches for me!)

Report account numbers at your bank that are involved in the activity being reported. So yes, you would include the account number, even though it does not belong to the suspect. Do not let this throw you off.

Thank you so much!