BSA SARs vs NON SARs

[Patricia Hardy]

We were recently told by an examiner to file a SAR for the following scenario: Customer almost fell victim to a scam but did not lose money but amount was over $25K. We have no information on the suspect (scammer). The $25K involved was never transmitted to the scammer. The customer realized they were being scammed or suspected something was not right and contacted the bank. The only reason we were made aware of this scenario is the customer came in and out of abundance of caution closed the accounts involved. Curious if others would file a SAR or decide it is a NON SAR. Whoever ultimately reads the SAR has nothing to go on but add it to a tally of scams.

[Kerri Martin]

If I don’t have any information that would be of value to law enforcement, I do a NON SAR.

[Susana Castro]

The examiner is going textbook on this. It is the intent, and it is over the 25k for unknown suspect. Law enforcement may see a few SARs coming in from different institutions reporting similar activity/attempts and may start to piece things together on a larger scale. Did the customer provide any information phone number, email, they had information on who to transmit to just never did because they realized it was a scam, any information helps in some way and that is what they are expecting.

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