Compliance Question of the Week

What activities are considered “suspicious” when I’m considering whether or not to file a Suspicious Activity Report (SAR)?

Suspicious activity is any conducted or attempted transaction or pattern of transactions that you know, suspect or have reason to suspect meets any of the following conditions:

  • Involves money from criminal activity
  • Is designed to evade Bank Secrecy Act (BSA) requirements, whether through structuring or other means
  • Appears to serve no business or legal purpose and for which available facts provide no reasonable explanation
  • Involves use of the credit union to facilitate criminal activity

Here are a few questions to that may signify a red flag:

  • Is the transaction amount larger than normal for the member?
  • Does the member make the same or relatively similar transactions more frequently than normal?
  • Does the type of transaction seem unusual for the member?

Related Links

31 CFR 1020.320

Questions? Contact the Compliance Hotline: 1.800.546.4465,

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