I have a question about item # 27 on the SAR (Financial institution TIN and account number(s) affected that are related to subject).

For example, our customer sent an outgoing wire and ended up sending it to the wrong beneficiary because their vendor's email was hacked and they were suppled updated wiring instructions (that were fraudulent). Our customer took the loss.

In item # 27, do we just put the information for the beneficiary bank account of the wire? Or do we also include our customer's account information...?

Thanks.

I would be listing the beneficiary of the fraudulent wire instructions as a subject. And per the SAR filing instructions,

"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 would say that the wire beneficiary likely owned or had control over the account. As far as your customer's account number, I wouldn't say that the subject had control or conducted activity in or through the account (since this isn't an account takeover or fraudulent check). It was your customer that had control and conducted the activity, not the scammer. You could list your customer's account number in the narrative for whatever it's worth.

So I would just list the beneficiary account number there. It might be useful if other SARs are filed with this account number listed in that field, rather than just in the narrative.