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#869416 - 12/07/07 11:05 PM Employee of Customer Embezzling
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
At about the same time as our customer - we realized their employee was embezzling from their account.

Our customer contacted the police & the employee is now in jail awaiting trial.

Do we need to file a SAR?
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My opinions are my own, and not that of my employer.

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#869425 - 12/07/07 11:24 PM Re: Employee of Customer Embezzling WonderWoman
ktac MITCH Offline
Diamond Poster
ktac MITCH
Joined: May 2005
Posts: 1,813
Giant side of TX
I say yes - Instructions of when to file a SAR says
(b) Violations > $5,000 & suspect can be identified
. . . [illegal] transactions conducted through the financial institution where [bank was victim] . .or the financial institution was used to facilitate the transactions.
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#869504 - 12/09/07 01:14 AM Re: Employee of Customer Embezzling ktac MITCH
complianceman Offline
Platinum Poster
complianceman
Joined: Mar 2005
Posts: 687
New Albany, IN
I agree. If you are aware that your institution was involved in the activity.
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#870594 - 12/11/07 06:14 PM Re: Employee of Customer Embezzling complianceman
CantBeShocked Offline
Gold Star
Joined: Apr 2006
Posts: 260
MS
I have had the same situation and yes, you file a SAR.
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#871588 - 12/12/07 07:15 PM Re: Employee of Customer Embezzling CantBeShocked
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
Most definitely. File, assuming the $5,000 threshold has been reached. Failing to file in similar situations was one of the big issues involved in AmSouth's $10 million civil money penalty in 2004.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

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