Posted By: PrimeTime
Subject Identification for SAR Reporting - 01/29/15 09:42 PM
I might really be overthinking things and making matters more complicated than they should be, however I recently came across a case a situation that made me question the SAR filing guidelines.
The FFIEC Guidance states that federal regulations require SAR filing with respect to:
-Criminal Violations aggregating $5,000 or more when a suspect can be identified
-Criminal Violations aggregating $25,000 or more regardless of a potential subject
What constitutes subject identification? Gut instinct says "if you've identified the name of a person", however I think it can also be interpreted as "identified to the point where all critical fields on the SAR regarding subject information can be filled". This is due to a potential filing where the subject is a non-customer, and the information for all critical fields is incomplete.
The FFIEC manual itself is rather cut and dry regarding this, I was wondering if there was an guidance released by FinCEN on this, or if anyone had a take on it?
The FFIEC Guidance states that federal regulations require SAR filing with respect to:
-Criminal Violations aggregating $5,000 or more when a suspect can be identified
-Criminal Violations aggregating $25,000 or more regardless of a potential subject
What constitutes subject identification? Gut instinct says "if you've identified the name of a person", however I think it can also be interpreted as "identified to the point where all critical fields on the SAR regarding subject information can be filled". This is due to a potential filing where the subject is a non-customer, and the information for all critical fields is incomplete.
The FFIEC manual itself is rather cut and dry regarding this, I was wondering if there was an guidance released by FinCEN on this, or if anyone had a take on it?