SAR for ATM Skimming Device

Posted By: Kristen C.

SAR for ATM Skimming Device - 07/17/13 01:30 PM

One of our ATMs had a skimming device attached to it last Friday. A customer noticed it when he went to use the ATM, he pulled it off of the machine and notified the police and our bank right away. The police came and took the device. We were able to view the camera footage and could see two men attaching the device to the machine about 2 hours before our customer used it. Our Operations department blocked the debit cards that had been used during that time frame and no accounts suffered losses. Lucky for us it was a rainy day and not many folks were using that ATM.

My question is since there was no loss at all do I need to file a SAR?
Posted By: Elwood P. Dowd

Re: SAR for ATM Skimming Device - 07/17/13 01:56 PM

Can you identify any specific amount of money involved in the attempt? Can you identify either of the men you have on camera?

Whether your bank suffered a loss does not determine whether a filing is required.
Posted By: BetsyS

Re: SAR for ATM Skimming Device - 07/18/13 12:31 AM

What about non-customer cardholders using the ATM? If there were any, have you notified their issuers?
Posted By: Kristen C.

Re: SAR for ATM Skimming Device - 07/18/13 04:16 PM

We cannot identify either of the men, no money was taken by them. Luckily it was a rainy night and there were only a few transactions done when the device was attached. The cards that were our customers were blocked immediatley and none lost any money. There were a handful of other bank customers involved and we notified those banks. As far as I know no customers had any transactions posted to their accounts. The device was not a wireless one so when our customer removed the skimmer and turned it over to the police it still had the info on it.
Posted By: John Burnett

Re: SAR for ATM Skimming Device - 07/18/13 06:56 PM

I'd say that filing a SAR in these circumstances would be optional. You can't identify the perps; you could indicate in the narrative that you have video, but don't recognize the bad guys. I think its usefulness to law enforcement would be minimal.
Posted By: devsfan

Re: SAR for ATM Skimming Device - 07/18/13 09:04 PM

Also, since the police are aware of the situation (probably before the bank was) and have the device there is no benefit or need to file a SAR.
Posted By: Indy Banker

Re: SAR for ATM Skimming Device - 07/23/13 04:11 PM

I agree, this sounds like a matter for state or local law enforcement to investigate. I can't imagine FinCEN/IRS investigators being interested. It can't hurt to file, but we would most likely not file with the situation you describe.
Posted By: ComplianceBanker

Re: SAR for ATM Skimming Device - 09/18/15 04:30 PM

Follow up from a topic a while ago, but say a bank were to file a SAR for the skimming of more than 99 of debit cards with an unknown subject. What would the expectation be with regards to completing item 24? Would we be expected to input 99 accounts associated with the cards? Seems like law enforcement would only be interested knowing that a skimming incident had occurred but since we know the accounts involved perhaps we should be including account numbers.
Posted By: Elwood P. Dowd

Re: SAR for ATM Skimming Device - 09/18/15 04:36 PM

If you believe filing a SAR is required, you need to provide all the information you have.
Posted By: Daisy Doodle

Re: SAR for ATM Skimming Device - 09/18/15 04:53 PM

You could attach the numbers as a file to your SAR.
Posted By: Beachbum, CRCM

Re: SAR for ATM Skimming Device - 09/18/15 06:22 PM

Agreed. With that many numbers, I would attach a file.
Posted By: John Burnett

Re: SAR for ATM Skimming Device - 09/18/15 07:12 PM

Absolutely. These accounts aren't the subject of your report, after all. They are just where the transactions ended up.
Posted By: Always In Training

Re: SAR for ATM Skimming Device - 02/22/17 06:13 PM

Reviving a dead post, because this is our current nightmare. I called FinCEN about the account numbers, because the data thieves got card data and PINS, and cash at other places. Still unknown subjects. I called FinCEN, because the thieves got card numbers, not account numbers. FinCEN rep held that because the activity occurred through the accounts, even though the subjects don't have the account numbers and didn't have control over the accounts, they had control of the linked cards. So, I will have to put all my affected customers' account numbers into item 24.

Edited to add: I'm reviving in case someone else searches for info about ATM skimming SAR reports. There isn't a lot of guidance out there as to what should or shouldn't be on the form.
Posted By: NBT

Re: SAR for ATM Skimming Device - 02/22/17 09:37 PM

We recently filed an ATM skimming SAR for many affected accounts and did not add the account numbers into item 24. The account numbers were provided in the transaction details tab that we use in BAM (banker's toolbox). So ultimately they were submitted.