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#2184778 - 07/10/18 05:22 PM SAR - More Than 99 Subjects - How to file
ItNeverEnds CRCM Offline
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Ok, this seems like a really stupid question, but I'm working on a SAR and I have more than 99 subjects (lots of checks issued to multiple different people). The form only lets you add 99, so how do you file when you have more subjects than that? I've searched, including the forums here, and I couldn't find an answer. Anyone have any thoughts? The only thing I could think of is to file this one and then file and amendment with additional subjects.

Thanks in advance for any guidance.
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#2184786 - 07/10/18 06:51 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
SmallBankBSA Offline
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WOW that must be quite the SAR! I would contact FinCEN for their guidance. I believe if you file an amendment to the a SAR it wipes it out like it never happened and gets replaced with the new SAR.
Good luck!

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#2184791 - 07/10/18 07:27 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
Princess Romeo Offline

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Offhand I would think you name the additional subjects in the narrative after explaining that there are more than 99 subjects involved and here are the subjects that could not be included in the subject fields. But as suggested, FinCEN should be the one to provide guidance.
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#2184792 - 07/10/18 07:29 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
TryingtoComply Offline
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Please let us know what FinCEN advises. Just curious.
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#2184796 - 07/10/18 07:41 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
BrianC Online
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Similar topic, different field. I had a client file a SAR due to a debit card data breach which involved more than 99 card numbers. FinCEN advised the bank to create a .csv file of the account numbers and describe the content of the attachment in the narrative.
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#2184797 - 07/10/18 07:42 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
BrianC Online
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To ItNeverEnds question. If these are counterfeit checks, do we really believe that all the recipients are truly subjects or are these money mules who won the UK National Lottery, were hired as secret shoppers, sold an item on Ebay of Craig's list and received a check for more than the agreed purchase price, etc.


These folks may actually be victims and would not be listed in Part I.
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#2184801 - 07/10/18 07:55 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
ItNeverEnds CRCM Offline
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Thanks for everyone's comments. I'm down to the wire to file and didn't realize until we started compiling all the names that we'd be over 99, and I'm sure FinCEN will take forever to get back to me. So I may have to file with what I think is best to avoid a late SAR.

To answer Brian, these aren't counterfeit checks, but receivers of marijuana related funds, so I think they all need to be listed as subjects. Each one on their own isn't a huge amount, but there are a lot of them.
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#2184817 - 07/10/18 08:41 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
JacF Offline

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The MRB is your depositor, and the 99+ are payees on their various transactions?

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#2184832 - 07/10/18 09:11 PM Re: SAR - More Than 99 Subjects - How to file JacF
ItNeverEnds CRCM Offline
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Originally Posted By JacPCB
The MRB is your depositor, and the 99+ are payees on their various transactions?


Not quite, our customer is providing services to some marijuana businesses, and the funds are moving through our bank by means of wires, ACH and then the checks are to people that work for the marijuana business. I don't want to be too specific in a public forum.
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#2184896 - 07/11/18 03:43 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
#Just Jay Offline
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I believe you can just attach a .csv file to your filing.
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#2184997 - 07/11/18 07:37 PM Re: SAR - More Than 99 Subjects - How to file ItNeverEnds CRCM
TryingtoComply Offline
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The West
So, your customer was getting a kickback for allowing their account to be used to move the funds?
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