SAR Filing Question

Posted By: Sherri B

SAR Filing Question - 03/23/17 02:49 PM

Question on an SAR I'm trying to complete. I have an elder exploitation case involving wire fraud. I'm listing all the individuals that received money from the elderly man as suspect as I know we cant include the elderly man as a suspect but reference him in the narrative. I just had new information brought to me regarding this case that should be included on this SAR, but I would have to include him as a suspect. He took out cash (also structured) for what I believe to bring to another bank to wire out more money as he doesn't think he's being scammed. Would I include him as a suspect in the elder abuse SAR and detail in the narrative my reason behind it, or file a new SAR, and reference the elder abuse SAR in the new SAR with the cash activity? Sorry if this is confusing! Any insight you have would be much appreciated.

Posted By: Midwest BSA

Re: SAR Filing Question - 03/23/17 03:20 PM

Yuck. If it were me, I'd probably just do 1 SAR since it's all tied together. List him as a subject, but be sure to explain your reasoning in the narrative. That's most likely the cleanest way to do it.
Posted By: bcompliance

Re: SAR Filing Question - 03/23/17 04:04 PM

I agree with 1 SAR. Did the people who are taking advantage of him advise him to structure the funds from the other bank? That may also play a part in the subject vs. narrative scenario.
Posted By: RockChucker, CAMS

Re: SAR Filing Question - 03/23/17 05:58 PM

Agree, 1 SAR should be sufficient and just make sure your narrative covers all the details.

Good luck.