We have a customer and non-customer that applied for a mortgage. The non-customer does not have any form of identification. He does not have a TIN either. He stated he had income from a local farm that he works at but does not have a work visa. I can see where this is heading but do you think it warrants a SAR filing?
Thank you!!
Posted By: Daisy Doodle
Re: Does this warrant a SAR? - 03/22/17 03:11 PM
He didn't lie to you, or put fraudulent info on the application. What would be your basis for filing?
He did not have a SSN or work visa but is collecting a paycheck. Possibly (probably) an undocumented immigrant. I'm just wondering if it's really up to FI's to report this type of thing if we are suspicious of it.
Based only on the information you provided I don't see where filing a SAR is necessary. The course of action you might take is to decline the mortgage application.
RockChucker-We did deny the loan but I'm just concerned we might get criticized by our regulator for not reporting it.
Posted By: Elwood P. Dowd
Re: Does this warrant a SAR? - 03/22/17 03:33 PM
Okay, if you had to file a SAR, think about what the narrative would say: "Based solely on his statements, we believe this person is working illegally in the U.S." I can't think of what the next sentence would be other than to acknowledge that it's a defensive filing.
Thank you all! I guess I was overthinking it. Time for a vacation!
Posted By: edAudit
Re: Does this warrant a SAR? - 03/22/17 04:08 PM
I will take the opposite conclusion based upon and recent non related exam "findings"
â—¦May involve potential money laundering or other illegal activity (e.g., terrorism financing).
https://www.ffiec.gov/bsa_aml_infobase/pages_manual/OLM_015.htm
Thank you edAudit for your feedback!