If a couple is using their childs TIN to open and close Deposit accounts and it appears to us that the funds are not being "used" by the child, should we be filing an SAR?

Do we just let the IRS worry about it?

Has anyone discussed the activity with the parents? You could always take the approach of trying to find out what they are doing so you can better align your products with their needs. If they're evasive and have no apparent reason for using their child's TIN, you might not need to file a SAR (unless the activity is of high dollar amounts), but contacting local law enforcement for advise might not be a bad move (just be careful not to name names for privacy's sake).

You don't indicate what the nature of the abuse is, but if it is limited to reporting the income under the wrong TIN, you won't find any support from the SAR instructions or regulations that suspected income tax evasion is even reportable. Also, at today's rates, the fund would have to be significant in order produce income reaching the $5,000 threshold.

If you believe the funds are not being applied correctly, you may want to make certain the parents understand the account they have opened and, if they persist, simply close the account. Misuse of the child's funds is a civil matter between the custodian and the child, not a potential violation of federal criminal law that would spur a SAR filing.