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#2250057 - 03/03/21 09:24 PM Two Financial Institutions on a SAR???
Couples Offline
Gold Star
Joined: Apr 2009
Posts: 280
The Igloo
We have a customer that is making suspicious ATM deposits via cash and we are filing a SAR. One of the suspicious transactions was at another bank's ATM. Should we include that other financial institution's information on the SAR and have two Part IIIs? Thank you!

I apologize if this has been answered.
Last edited by Couples; 03/03/21 09:25 PM.
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BSA/AML/CIP/OFAC Forum
#2250162 - 03/05/21 08:48 PM Re: Two Financial Institutions on a SAR??? Couples
Compliance Slave Offline
Junior Member
Joined: Nov 2006
Posts: 40
Fresno, CA
I have the same question.

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#2250681 - 03/16/21 06:29 PM Re: Two Financial Institutions on a SAR??? Couples
Couples Offline
Gold Star
Joined: Apr 2009
Posts: 280
The Igloo
I just today received a response from FinCEN. They indicated we should add the other Financial Institution and have two Part IIIs. That is disappointing. Not only the length of time it took to get a response, but that is not how we filed so an amendment is necessary. But now we have it for future use.

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