SAR Form Specifics

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Question:

We are debating Item 24 on the SAR form, Financial Institution TIN and Account affected. The scenario is this - a bank customer cash structured his transaction by cashing two checks on two separate days drawn off of another bank customer. Do you include the account number of the two checks cashed even though the cashier has no ownership to the account?

Answer:

An account is related to a subject if the subject owns the account, has control over the account, or conducted activity in or through an account the subject does not own or control.