Today 6:10 am
You run an AML Dept.Beekeeper » 23 minutes ago » wrote: ↑ Yes.
SAR Filing RulesCHASE ME SOME MORE, cupcake!!
- Standard of Suspicion: Banks are only legally required to file a SAR through the Financial Crimes Enforcement Network (FinCEN) if they "know, suspect, or have reason to suspect" that a transaction involves criminal activity or violates the Bank Secrecy Act
Your employer is fined, and you will have a narrative attached to your publ8c FINRA profile if regulators conclude that your process failed to identify a series of "suspicious" transactions....
There is NO sanction in the event your SAR was mistakenly filed for a non criminal transaction.
As the dept manager are YOU going to try to determine whether a transaction is "criminal", or are you going to file SARs for ALL transactions which demonstrates the general characteristic of those considered reportable in your firm's WSP?