Posted By: Sunpokey
SAR IOLTA - 02/16/18 08:36 PM
If we have an IOLTA account that we are filing a SAR on, would the Law office be a subject, if the activity being filed on was for a
client and had nothing to do with the business itself?
Posted By: BrianC
Re: SAR IOLTA - 02/16/18 08:44 PM
If the law office is not involved in the suspicious activity, it is not a subject. It may be appropriate to list the law office in the narrative if it helps to tell the story of what you suspect. No different than not including a scam victim as a subject even if the transactions passed through their account.
Posted By: Sunpokey
Re: SAR IOLTA - 02/16/18 08:50 PM
If the client the law office is representing has given them cash derived from illegal activity who is the subject of the SAR?
Posted By: 80's Lady
Re: SAR IOLTA - 02/16/18 09:33 PM
The client. If the law office is aware and complicit, they would also be a subject (i.e. assisting them with laundering the funds).
Posted By: MollyM
Re: SAR IOLTA - 02/20/18 03:29 PM
If you know that the law office was aware of and complicit with the activity in question, then, yes, you definitely include the attorney/law office.