Does the responsibility to file a SAR rest on whether or not a loss has occurred?
When filing a suspicious activity report (SAR), it does not matter if your institution suffered a financial loss or not. The law requires a SAR filing if the suspicious transaction involves at least $5000 and you know or suspect that the transaction involves funds derived from illegal activities or is intended to hide or disguise funds; is intended to evade BSA requirements; or, has no apparent lawful purpose or is not the type of transaction one would expect from the particular customer conducting the transaction. Additionally, the enforcement action against AmSouth Bank specifically stated that SAR filings are not contingent on bank losses.
