SAR Filing Reminder

Financial institutions are required to file a Suspicious Activity Report (SAR) for any suspicious activity that meets certain thresholds, including:

• Inside abuse involving any amount
• Transactions aggregating $5,000 or more where a suspect can be identified
• Transactions aggregating $25,000 or more regardless of potential suspects
• Transactions aggregating $5,000 or more that involve potential money laundering or violations of the Bank Secrecy Act.

As you dig deeper into these thresholds, you will notice that the regulatory verbiage refers to …Any known or suspected Federal criminal violations, or pattern of criminal violations committed or attempted against the bank or involving a transaction or transactions conducted through the bank…. It’s very clear that you are to file SARs on any suspicious activity that meets these thresholds and not just suspicious or criminal activity that was actually proven or accomplished. For instance, if someone lies on a loan application to help them get a loan, that is loan fraud and if it exceeds an applicable threshold, a SAR is required. It doesn’t really matter if you deny the application to prevent the fraud or not. This is an area that is often overlooked.

Kevin discussed this during our AML/CFT Group. Check it out!