SAR requirements connect banks to these proposed rules for real estate activities. Bankers who keep themselves aware of what other industries have to do for their BSA/AML/CFT requirements will be more attuned to activities that, if seen by a banker, should be reported. For example, if a bank discovers that a large number of its cashier's checks in moderate amounts have been negotiated at the same time and the indorsements suggest they were involved in a real estate transaction involving a huge sum (such as a couple of million dollars), the bank might well wonder why so many small cashier's checks, purchased over several weeks with several different payees appear to have been negotiated in a single real estate deal of such a size. That could trigger a SAR filing.
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John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8