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#1084120 - 11/19/08 04:13 PM Penalties for not filing a SAR?
complygirl Offline
Platinum Poster
Joined: Oct 2004
Posts: 822
midwest
An examiner recently suggested that we begin filing SARs on one of our customer for ongoing activity that seems suspicious. If we choose not to file a SAR, and it's later determined that we should have filed a SAR on this customer can we be fined for not having filed a SAR?

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BSA/AML/CIP/OFAC Forum
#1084126 - 11/19/08 04:17 PM Re: Penalties for not filing a SAR? complygirl
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,049
Dallas, TX
Originally Posted By: complygirl
An examiner recently suggested that we begin filing SARs on one of our customer for ongoing activity that seems suspicious.


Is the activity suspicious or not?

If it is, you should be filing.
If it isn't, you should have documentation to support why it's not.
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

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#1084159 - 11/19/08 04:47 PM Re: Penalties for not filing a SAR? complygirl
M Cockrell Offline
Diamond Poster
M Cockrell
Joined: Jan 2003
Posts: 1,049
Dallas, TX
also see pg 66 of the BSA/AML Exam Manual
_________________________
"Remember no man is a failure who has friends." - Clarence (the Angel) Oddbody - It's a Wonderful Life

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