Attempted transactions

Posted By: ComplianceBanker

Attempted transactions - 04/10/15 12:36 PM

Was hoping to get some thoughts with regards to completing SARs on attempted transactions and the characterizations that might apply.

A hypethitical scenario would if a customer conducted structured cash deposits into their account and then attempts to send an outgoing wire. The bank refuses to complete the wire transaction as the customer would not provide information with regards to whom the beneficiary is or the purpose of the wire.

Would item 33e (suspicious eft/wire transfers) be selected or would the wire information just be information for the narrative?
Posted By: rlcarey

Re: Attempted transactions - 04/10/15 12:54 PM

A financial institution must report any transaction that requires reporting under the terms of 31 CFR Chapter X if the transaction is conducted or attempted by, at, or through the financial institution.

If you are reporting on an attempted wire that you thought was suspicious, why would you choose not to check the box.