Determining When to File a SAR

Every financial institution needs to establish a system to identify suspicious behavior, investigate the underlying facts, and initiate a Suspicious Activity Report in the appropriate circumstances. And don’t forget to take time to fine tune your BSA/AML/CFT processes. If one step fails, the entire process is compromised, and you are at risk of potential BSA violations – which could include monetary penalties or even criminal charges.

What if you’ve looked at a suspicious set of facts over and over again and cannot decide if it rises to the level of a SAR? Your financial institution needs to have an effective process of identification, evaluation, and reporting of suspicious activities. But once you get past the enumerated events which require a filing, there are still vast possibilities. This session will review the primary components of the SAR decision, while also uncovering the hidden landmines using real-world experience, regulatory examinations, and FinCEN enforcement actions.