We have a customer in which 2 wires were sent out and found out it they were fraudulent. We, the bank, did call back verification appropriately but the person that verified didn't realize that it was a fraudulent email address until after they were sent. Now, it appears they may have check fraud going on. Does this constitute a SAR being done?

Do you have a suspect - and what's the dollar amount of the wires?

FinCEN's advisory on email compromise schemes will give you all the info you need evaluating if a SAR should be filed and how it should be completed if it is needed.

https://www.fincen.gov/sites/defaul...dated%20BEC%20Advisory%20FINAL%20508.pdf

We don't have a suspect and they were $8,000 each.

Thank you!!

I might consider the wire counterparties as a suspect if they are receiving funds as part of a fraud scheme. FinCEN also has a designated cyber event box for suspicious email addresses. So you might actually have a suspect depending on the facts and circumstances.