Questions and Answers

No.  The BSA regulations make no mention of suspicious activity report (SAR) filings being contingent on whether or not a loss to the financial institution has occurred.  Rather, the law requires a SAR filing if the transaction involves at least $5000 and you know or suspect that the transaction involves funds derived from illegal activities or is intended to hide or disguise funds; is intended to evade BSA requirements; or, has no apparent lawful purpose or is not the type of transaction one would expect from the particular customer conducting the transaction.  See 31 CFR 103.18.  In addition, in past enforcement actions, the regulators have said that SAR filings are not contingent on bank losses.