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Two Individuals: Two Accounts: Two SARs?

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Question: 
I had two individuals come into the bank with one check and opened two separate individual checking accounts. A few days after the account was opened they began withdrawing large sums of cash below $10,000 from these accounts on a daily basis. Should I complete one SAR with two suspects or two separate SARs?
Answer: 

Less is more. Since this involved, at the start, a single check, it's likely these two suspects are involved in whatever they are doing together, rather than separately. Putting the whole enchilada in a single SAR gives law enforcement a more complete and concise view of what you believe may be happening. List both individuals as suspects, and tie the thing up in a pretty bow in your narrative, where you'll explain that it all started with that one check and that they came in together.

First published on BankersOnline.com 7/05/10

First published on 07/05/2010

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