Skip to content
BOL Conferences Top Gun 23
Thread Options
#1796449 - 03/19/13 11:30 PM Request for SAR supporting documents
ABT Offline
Junior Member
Joined: Nov 2010
Posts: 32
The Dept. of Homeland Security called us about requesting supporting documentation for a recently filed SAR. An agent from the department will be visiting us in person to request & obtain those documents. We have not had a request like this before, so I would like to get some guidelines prior to this visit. In addition to requesting to see the agents credentials when he arrives at the bank, is there anything else that I need from him? Do I need to have this request in writing for our documentation & retention purposes? Is it correct that we should only supply supporting documentation that was referred to in the SAR?

Return to Top
BSA/AML/CIP/OFAC Forum
#1796450 - 03/19/13 11:42 PM Re: Request for SAR supporting documents ABT
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 80,393
Galveston, TX
In addition to requesting to see the agents credentials when he arrives at the bank, is there anything else that I need from him?

Not really.

Do I need to have this request in writing for our documentation & retention purposes?

It would be nice but not required

Is it correct that we should only supply supporting documentation that was referred to in the SAR?

Absolutely
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#1796482 - 03/20/13 01:07 PM Re: Request for SAR supporting documents ABT
Cape Codder Offline
Gold Star
Joined: Jul 2011
Posts: 413
When we receive such a request, we do require that it be confirmed in writing and that it includes the DCN of the SAR in question. We also independently authenticate his/her authority, etc. before complying with the request.
_________________________
Nothing difficult is ever easy.

Return to Top
#1797056 - 03/21/13 02:52 PM Re: Request for SAR supporting documents ABT
joser Offline
Member
Joined: Sep 2005
Posts: 68
NJ
Just my opinion, use caution if they attempt to engage in conversation re the subject which is outside the scope of supporting docs.

Return to Top
#1797089 - 03/21/13 03:25 PM Re: Request for SAR supporting documents ABT
Kathleen O. Blanchard Offline

10K Club
Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,292
Of course, if they provide a subpoena they can have the other data. When contacted, I often also received a subpoena.
_________________________
Kathleen O. Blanchard, CRCM "Kaybee"
HMDA/CRA Training/Consulting/Mapping
The HMDA Academy
www.kaybeescomplianceinsights.com

Return to Top
#2269265 - 04/18/22 04:19 PM Re: Request for SAR supporting documents Kathleen O. Blanchard
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,038
Dallas, TX
I'm new to the BSA Officer role.

Recently received a call from an alleged DHS Agent requesting SAR supporting documentation.

He asked for me e-mail address (which I provided) and he sent me an e-mail asking that I "...accept this email as a request for the supporting documentation associated with..." SAR ####.

There was no attachment (subpoena, summons, warrant, etc.).

Is this legit? Is this how the DHS would normally make a request like this?

Please advise.
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

Return to Top
#2269279 - 04/18/22 04:51 PM Re: Request for SAR supporting documents ABT
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,691
The Country
Not unusual for a department of law enforcement to reach out and ask for the supporting documentation for a SAR that was filed so they can look into it and see if it makes sense to pursue it. That said, I make sure I identify the individual (make sure they work for that department and does the email look legit) requesting the information prior to sending out the supporting documentation. If they are asking for additional information that was not included in the SAR then I ask for a subpoena.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

Return to Top
#2269284 - 04/18/22 05:30 PM Re: Request for SAR supporting documents ABT
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,242
New York City
Law enforcement does not need to supply a subpoena for SAR supporting documentation. If they have the correct DCN for the SAR and the email is coming from the appropriate @ handle, I think you have a legit request.
_________________________
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

Return to Top
#2269285 - 04/18/22 06:10 PM Re: Request for SAR supporting documents ABT
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,038
Dallas, TX
Thank you for the responses.

The following was brought to my attention: https://www.fincen.gov/index.php/re...activity-report-supporting-documentation (paragraph 3).
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

Return to Top
#2269335 - 04/19/22 03:15 PM Re: Request for SAR supporting documents ABT
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 279
-
i do a cold call back to the agency etc. they identified themselves as being with first to determine if the party requesting is in fact who they say they are and who they say they are with.
_________________________
plan your Work and Work your Plan

Return to Top
#2269337 - 04/19/22 03:19 PM Re: Request for SAR supporting documents ABT
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,038
Dallas, TX
Agreed. Thank you.
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

Return to Top
#2269357 - 04/19/22 06:28 PM Re: Request for SAR supporting documents ABT
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,608
Pulling people out of the ditc...
our local FBI office frequently provide their cell numbers for callback, we tell them send us an email on their FBI address with what they are looking for, and make sure their office and cell number are included there. And we also have a central point of contact in the bank that these are all filtered to, which helps us as well
_________________________
Providing alternative truths since the invention of time

Return to Top

Moderator:  Andy_Z