SAR - Total amount involved

I have a customer who is kiting:

day 1 -Deposited check from Bank ABC to Bank DEF in amount of $5,000
day 2 -Deposited check from Bank DEF to bank ABC in amount of $5,000

Day 8- deposited check from bank ABC to bank DEF in amount of $6,000 DEF placed hold on deposit.
Day 9 - deposited check from day 8 was returned NSF to bank DEF.

Would you total all deposits & checks for the SAR, making it transactions totalling $16,000?

I would indeed do that.

IMO we are talking about all those funds being involved in the suspicious activity. If you have reason to believe (proof) some of the funds weren't involved in the activity, exclude them. Otherwise $16,000 is what my SAR would read.

Cheers!

Thanks so much. I appreciate your input.

By the same token, if a customer receives a wire for $100,000 and then writes a check for the same amount back to the originator, would you file as $100,000 or $200,000?

When I file SARs, I do so on the transaction. So transaction #1 was the incoming wire for $100K. Transaction #2 was the outgoing check for $100K. If I deem each individual transaction to be suspicious, then I file on 2 transactions for a total of $200K.

There's been a ton of back and forth on this type of question which you can find varying answers for if you search.

Overall, the best take I've seen (I believe it was from Ken P) is to make a habit of explaining your calculation within the narrative. It provides protection against audit/exam findings and in many cases actually does help the reader fully understand what you consider suspicious.

I'm in the camp of evaluating per transaction (whether completed or not). Loan application? Put the requested amount. Kiting? Add up all of the incoming transactions and outgoing transactions involved in the scheme. Kiting is the most controversial in that regard.