Wanted to poll what other FIs are doing...

In situations where your customer is a scam victim sending/receiving funds, whether through check deposits/purchases, wires, etc., are you listing the payees/beneficiaries of the funds as potential suspects or potential victims that are likely also being scammed and used as mules?

We list our customer as the victim and everyone else as potential suspects.

We do the same. We also are conducting 314(b) information requests with participating banks and including as much additional information as we are able.

we do the same - customer is the victim and all others as potential suspects

Thanks for the feedback everyone!

We had a customer come in to withdraw $10,000 because they were called and said there was an "internal investigation" of another withdrawal coming out of their account. They were instructed to get the funds and then call for further instructions. The Bank convinced them this was a scam, and no funds were withdrawn. We do not have a suspect name and no transactions were done.

Do we still fill out a SAR even if the amount is less than $25,000?

No suspect - no reporting under $25,000. You could voluntarily report, but I would do that if I had information that I thought would be valuable to law enforcement. In this case you have nothing.

I don't see a SAR either, but i hope you encouraged them to file a police report, including providing the number they were supposed to call once the funds were secured. and hopefully your police department takes action, some are really good, some are Barney Fife...