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: https://www.fincen.gov/sites/default/files/shared/FinCEN%20SAR%20ElectronicFilingInstructions-%20Stand%20Alone%20doc.pdf
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