Ethical dilemma with SAR

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Question:

I work in the BSA/AML area at my financial institution. Recently we had an incident where a SAR needed to be filed on an accountholder. While the situation wasn’t major, it still required a SAR and our CEO told us not to file it. I am afraid of what could happen if I don’t follow his orders. This is a small town so the bank is the only major employer I can’t easily change jobs. No matter what I do f(ile the SAR or don’t file it) I cannot win. Help!

Answer:

While we understand your personal situation of not wanting to seek other employment, you may want to if the CEO violates the law. We would suggest you go back to the CEO and ask the reason for not filing the SAR. Perhaps we have a basic misunderstanding here. If the SAR must be filed you may have to file a second one for the CEO if he doesn’t change his mind. Requiring someone to violate a regulation without providing a reason makes this an ethical issue and a legal problem.
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