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Filing a SAR for Foreign Wire Account Funds

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Question: 
Scenario- A customer receives foreign wires for "family support." This customer also received an unsecured loan for a purpose of "family support". The customer withdrawals most of the account funds at casinos in cash and then makes cash deposits after winning money. The lender doesn't have a concern on the loan side. What is your opinion on filing a SAR?
Answer: 

You should consider a SAR filing even if it's only about the false statement concerning the purpose of the loan. I imagine your lender would be a lot less casual about the loan if the borrower loses the proceeds at the casino and can't pay the loan off.

First published on 10/27/2019

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