Skip to content
BOL Conferences
Thread Options
#2209982 - 04/01/19 03:16 PM ATM=Branch Location for SAR filing
IronP2717 Offline
100 Club
Joined: Feb 2018
Posts: 146
I have a SAR Filing where all activity occurred at one of our ATMs. I would think that would equate to a "branch location" for the purpose of completing the SAR form.

I'm not finding an explicit answer in the SAR FAQ's or the SAR form itself.

Does anyone know definitely?

Return to Top
BSA/AML/CIP/OFAC Forum
#2210065 - 04/02/19 12:59 PM Re: ATM=Branch Location for SAR filing IronP2717
Adam Witmer Offline
Power Poster
Joined: Sep 2010
Posts: 2,658
No, I don't know definitely as I have never seen this situation addressed in BSA guidance. Have you tried contacting FinCEN for guidance? We would be curious to know what they say.
_________________________
Adam Witmer, CRCM

All statements are my opinion, not those of my employer, and should not be taken as legal advice.
www.compliancecohort.com

Return to Top
#2210072 - 04/02/19 01:28 PM Re: ATM=Branch Location for SAR filing IronP2717
Richard Insley Offline
10K Club
Richard Insley
Joined: Oct 2000
Posts: 10,180
Toano, VA
You're on the right track. Law enforcement officers need physical locations in order to conduct investigations. Knowing the exact location of the ATM might help them put the pieces together to figure out what's going on.
_________________________
...gone fishing.

Return to Top
#2210075 - 04/02/19 01:43 PM Re: ATM=Branch Location for SAR filing IronP2717
HappyGilmore Offline
10K Club
Joined: Jun 2004
Posts: 19,857
Pulling people out of the ditc...
the activity occurred at the ATM located in the northeast corner of the branch facility located at 123 Bank Ave.
_________________________
Providing alternative truths since the invention of time

Return to Top
#2210077 - 04/02/19 01:53 PM Re: ATM=Branch Location for SAR filing IronP2717
IronP2717 Offline
100 Club
Joined: Feb 2018
Posts: 146
Happy,
That's essentially how I've included it in the narrative, but wanted to make sure I completed the check box correctly that answers branch activity and location. #68-74 on the SARX.

Return to Top

Moderator:  Andy_Z