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#2275841 - 09/21/22 02:08 PM SAR
Compliance Risk Offline
Member
Joined: Sep 2015
Posts: 81
If a customer has large ATM withdrawals from Casinos in the area, do you list the casinos as financial institution where activity occurred?

If there is only one owner for this company, would you report the owner who made the ATM withdrawals and other cash activity and the business?
Last edited by Compliance Risk; 09/21/22 05:58 PM.
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#2276033 - 09/27/22 03:52 PM Re: SAR Compliance Risk
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 316
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i am probably missing something but why would you file a SAR on a customer who withdraws from a ATM located at a casino?
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#2276048 - 09/27/22 07:26 PM Re: SAR Compliance Risk
Amy S Offline
100 Club
Joined: Sep 2020
Posts: 222
I would be looking at dollar amounts and normal activity for said person. One ATM withdrawal at a casino would not normally trigger my spidey senses. Millions of people do it. I would need more than that for a SAR.

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#2276071 - 09/28/22 02:59 PM Re: SAR Compliance Risk
SteveDave Offline
100 Club
Joined: Aug 2021
Posts: 124
If the large cash withdrawals are part of the SAR you should list that it is indeed a casino that the funds are being drawn at to be specific but I would not call a casino a financial institution. It could be part of the narrative. If you do not know it is the owner but you are assuming I would not indicate it was for sure them doing anything. it is the card and account issued to them. It is assumed it is them yes but that does not mean it was.

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