Compliance Alliance Q&A 3/31/2020

Q: Our bank is filing a SAR for a customer that brought in $2,500 in cash on eight separate occasions. The account in question is owned by a husband and wife, and we are not 100% sure who brought it in the cash deposits. We have filed SARs previously but in those cases, we knew the husband made the deposits because they were over $3,000. Do we need to add both the husband and wife to the new SAR?

A: For SARs, the bank should only file Part I's on subjects known to be involved in the suspicious activity, so if you know or suspect the husband is involved but you do not know or suspect that the wife is involved, you'd complete a Part I on the husband and describe the activity of the unknown transactions in Part V, the narrative section.
Complete a Part I section on each known subject involved in the suspicious activity.
If the suspicious activity involves known and unknown subjects, complete a Part I section on each known subject and record the nature of the unknown subject(s) in Part V. Do not complete Part I records on the unknown subjects when there are known subjects.
SAR Instructions, p. 88
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