Skip to content
GeoDataVision
Thread Options
#2262534 - 11/15/21 11:50 PM Unknown suspect SAR filing
Secret Squirrel Offline
New Poster
Joined: Jun 2017
Posts: 21
The SAR filing for an unknown suspect of $25K-got that. But was is the definition of an unknown suspect? What if we have a name and nothing else what about a partial name? how much information do we have to have to be considered we have suspect information? We have been seeing a lot of scams lately and we have partial names of suspects and have filed on some that are below the $25K and got to wondering how much info we should have to file. Does not make a lot a sense to just give a name and no other beneficial information for law enforcement.
Thank you

Return to Top
BSA/AML/CIP/OFAC Forum
#2262565 - 11/16/21 07:33 PM Re: Unknown suspect SAR filing Secret Squirrel
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 290
I've posed this question with FinCEN and been told a SAR is required if the bank has adequate information to provide on the SAR that would identify the subject; so it is somewhat subjective. There is also guidance in an old FinCEN review (I believe) that acknowledges that most times a name is associated with a scam, it's a fictitious name. I believe that if you believe you have the real name of a subject, you should report, even if that's all you have. If you just have a name that's listed as the "President" of a sweepstakes or something, you can probably document why you don't have a true subject so you don't meet the filing threshold. We often don't file these cases.

The safest course would be to just file though- choosing not to in a subjective area like this opens you up to more criticism from examiners. I also think it's worthwhile to consult FinCEN yourself if you want to rely on the guidance I referred to. It's not published, so you'd want your own record, and who knows if they've changed their thinking since then?

Return to Top
#2262617 - 11/17/21 09:46 PM Re: Unknown suspect SAR filing Secret Squirrel
Secret Squirrel Offline
New Poster
Joined: Jun 2017
Posts: 21
Thank you. I will reach out to FinCEN.

Return to Top

Moderator:  Andy_Z