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Employee Check Kite & SARs

Would there be a fine to a financial institution for not filing a SAR on an employee for check kiting?

Answer by David Dickinson:You are required to file a SAR for check kiting. Fines may be imposed for not doing so.


Answer by John Burnett:Because an employee is involved, there is no trigger level (zero tolerance). Once you're sure there is a kite going on, you need to act and a SAR filing really isn't optional in such a case.

Don't forget that, in addition to getting cited in an exam report for a violation, the integrity of your suspicious activity review and SAR reporting process can be called into question; the board of directors hears all about it, and the bank could get a cease and desist order. Monetary penalties could also follow, and the bank's ability to expand could be affected.

First published on 2/22/10

First published on 02/22/2010

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