Skip to content

Subpoena/Summon Reports for Former Customers

Question: 
Our recent examiner said we must work up a potential SAR report for summonses & subpoenas. Does this apply if the subpoena is on a former customer (currently closed)?
Answer: 

John Burnett

Poppycock! A summons or subpoena most definitely does not trigger a SAR filing, and you certainly cannot cite the receipt of a summons or subpoena in a SAR as a reason for filing.

If, during your research of records to comply with a summons or subpoena, you discover customer activity that appears suspicious, THAT activity would trigger the potential for a SAR, whether the account has remained open or has been closed.

Answer: 

Jim Bedsole

I wonder if the examiner was saying that the receipt of the summons/subpoena should at least trigger an investigation into whether a SAR should be filed. Even if so, I think that is a stretch.

First published on 08/25/2014

Filed under: 
Filed under compliance as: 
Filed under operations as: 
Filed under security as: 

Banker Store View All

From training, policies, forms, and publications, to office products and occasional gifts, it’s available here:

Banker Store

hot right now

image description

Looking for effective, convenient training on a particular subject?

BOL Learning Connect offers more than 200 courses ON-DEMAND or on CD ROM from AML to Reg Z and every topic in between.

Search Topics