Answer by Randy Carey: If that is part of the investigation file that is going to be made available as supporting documentation for the SAR, yes it should included be in the narrative. Why you would exclude details of this nature escapes me.
Answer by Ken Golliher: The Legacy form asks for any "confession." The FinCEN SAR asks for "corroborative statements." Their interest in the information is evident.
First published on BankersOnline.com 4/15/13