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Reporting SAR if Member of Board Is Involved

I was told by an examiner a few years ago that a bank is not required to report a SAR to its Board of Directors if the SAR involves a member of the Board. That provides protection for the person filing the SAR. Is that correct? If yes, where can I find that information? Thank you.

by David Dickinson:

Footnote #76 of the BSA/AML Exam Manual states:

As noted in the Bank Secrecy Act Advisory Group's The SAR Activity Review — Trends, Tips & Issues, Issue 2, June 2001, "In the rare instance when suspicious activity is related to an individual in the organization, such as the president or one of the members of the board of directors, the established policy that would require notification of a SAR filing to such an individual should not be followed. Deviations to established policies and procedures so as to avoid notification of a SAR filing to a subject of the SAR should be documented and appropriate uninvolved senior organizational personnel should be so advised."

You can find the Exam Manual here:


by John Burnett:

Two key elements of that exam manual guidance:

1. Make sure the subject of the SAR is not notified.

2. Have a procedure for notifying other appropriate management and board individuals in such circumstances.

First published on 10/18/2015

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