Training module created by:  Title 31 Testing, LLC

SARs - Review Scenarios

A casino is required to file a SAR if you “know, suspect or have reason to suspect” an activity or transaction is suspicious.  It is not required to have proof of any illegality, nor is it required to form a legal opinion.  It is the responsibility of the appropriate governmental agencies to analyze the SARs received from all reporting financial institutions and to investigate possible violations of the law.  The Bank Secrecy Act contains a “safe harbor” providing broad protection from civil liability to casinos, card clubs and their employees that file SARs or otherwise report suspicious activity.  The safe harbor applies whether the SAR is required or voluntary, and also protect the filer for not disclosing the fact that a SAR has been filed.

Part II of the new form lists 16 specific types of suspicious activity.  Because suspicious transactions may compromise more than one of the listed types of activities, the filer should check as many boxes as are applicable (but be sure to check at least one box).

Red Lake Gaming Enterprises, Inc

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