Answer:
I can't respond to this specific situation because I do not know the dollar amounts involved or whether you have a suspect. However, the general answer is, "Yes, if a threshold for SAR filing was met, you would file a SAR regardless of whether the bank was the intended victim." Several of the SAR filing omissions cited as the basis for criticizing AmSouth focused on fact situations where the bank was not the intended victim. Whether the bank actually lost money is not relevant to any SAR filing decision.
First published on BankersOnline.com 5/16/05