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#906637 - 02/19/08 06:03 PM SAR Filing Thresholds
Norrie Offline
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Joined: Feb 2008
Posts: 67
The FFIEC BSA/AML Exam Manual states that a SAR should be filed with respect to, "Criminal violations aggregating $25,000 or more regardless of a potential suspect." Yet, it also says a SAR should be filed with respect to, "Transactions conducted or attempted by, at, or through the bank (or an affiliate) and aggregating $5,000 or more, if the bank or affiliate knows, suspects, or has reason to suspect that the transaction:
* May involve potential money laundering or other illegal activity (e.g., terrorism financing)..."

What is the difference between a "criminal violation" and "illegal activity"? Would a SAR need to be filed if a forged check for $5,000 was deposited into a bank but there was no suspect?

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#906671 - 02/19/08 06:20 PM Re: SAR Filing Thresholds Norrie
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
The $5,000 threshold is if you know who the suspect is.

$25,000 threshold is if you don't know ...
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#906682 - 02/19/08 06:26 PM Re: SAR Filing Thresholds WonderWoman
Norrie Offline
Member
Joined: Feb 2008
Posts: 67
However, the Exam Manual does not indicate whether or not a suspect must be known when it states, "Transactions conducted or attempted by, at, or through the bank (or an affiliate) and aggregating $5,000 or more, if the bank or affiliate knows, suspects, or has reason to suspect that the transaction:
*May involve potential money laundering or other illegal activity (e.g., terrorism financing)..."

Does it have to do with where the suspicious activity occurred, i.e., "by, at, or through the bank" or elsewhere?

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#906780 - 02/19/08 07:23 PM Re: SAR Filing Thresholds Norrie
Deena Offline
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Deena
Joined: Nov 2000
Posts: 2,701
PA
I think it has to do with the type of criminal activity. If it's BSA-related (e.g., money laundering or terrorist financing), the threshold is $5,000 - even if you don't have a suspect. For other types of criminal activity (e.g., your example of a forged check), the threshold is $25,000 if you don't have a suspect.
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