We also have a separate fraud and BSA department, but all SARs are filed by the BSA department and we do all EDD reviews if our BSA risk model identifies the customer as high risk. But we would close an account if we felt the customer was involved in the fraud. In most cases, our customer is a victim.
I'm not a big fan of assigning extra high points within an AML monitoring system for SAR filings for this reason. In most systems you can't distinguish the customer that is a victim from the subject and the customer that is a victim gets tagged as being high risk when they may not be. For us, a customer that is the SUBJECT of a SAR is higher risk, but they are monitored every 90 days to determine if a supplemental review needs to be performed and we track them separately. When asked for a list of high risk customers we include any customers that are "active" SAR customers.
For context, we are over $10 billion.