Compliance Q&A: Joint Accounts and Suspicious Activity Reporting

Q: We have a joint account owned by three people. When filling out a SAR, do we include a Part I on an all account holder even if one had no transactions or involvement?

A: While a CTR has an assumption that all joint accountholders benefit from a deposit into a joint account, a SAR does not have that assumption. If a joint owner is not the transactor, and if the bank has no information that the transactions are on behalf of that particular joint owner, there is no need to specifically list them on the SAR as a subject.

For Reference: Part I Subject Information: Complete a Part I section on each known subject involved in the suspicious activity. Persons who are victims of the suspicious activity are not subjects and should not be recorded in a Part I section 

FinCEN, Electronic Filing Requirements for the FinCEN Suspicious Activity Report, p. 88:


Compliance rules and regulations change quickly! For timely compliance updates, subscribe to Compliance Alliance’s email newsletters. Compliance Alliance offers a comprehensive suite of compliance management solutions. To learn how to put them to work for your bank, call(888) 353-3933 or email and ask for our Membership Team.

Not a member? Learn more about membership with Compliance Alliance by attending one of our live demos: