Several years ago, I had just arrived on-site for a bank visit when the BSA Officer quickly pulled me into her office and shut the door. She had a dilemma: she had filed a SAR on a director and was faced with the challenge of how she was going to report that SAR to her board. Her challenge was that the board had a practice of viewing a copy of the entire completed SAR and if she continued on with this practice, should be be disclosing to the director that the bank had filed a SAR on him. This, of course, would be problematic for a number of reasons: unlawful disclosure and a very uncomfortable boardroom are two of them. Fortunately for this BSA Officer, I had a simple solution for her.
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