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Joint Acct-1 Spouse Conducting Suspicious Activity

Answered by: 
John Burnett

Question: 
I have a BSA question about a Suspicious Activity Report. It is a joint account with a husband and wife, but the husband is solely the one conducting the suspicious activity. We have had no interaction with the wife and have no suspicion of her -- she is a non-player in the event. When we file the SAR, how do we treat the wife? Is she a subject by default? She's not a victim. Do we leave her off entirely?
Answer: 

Unless you have reason the believe the wife is involved in the suspicious activity, she should not be named as a subject. I recommend including in the narrative the fact that the account is joint with (name of wife) but she does not appear to be involved in the suspicious activity.

First published on 01/23/2022

Filed under: 
Security
Filed under security as: 
Joint Accounts/Tenants
SAR

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