In April Lillian Redmond, the teller supervisor for First National Bank, discovers five counterfeit $20 bills in several teller drawers. In May and in June she discovers two additional counterfeit $20 bills. She has no knowledge of criminal activity on the part of any of the bank's employees or customers. She does not suspect any particular person in this transaction. Which of the following statements is true?
Ms. Redmond must report the counterfeit funds on a Suspicious Activity Report (SAR) but is not required to name any individual(s) on the report. Financial institutions are obligated to file a SAR for counterfeit instruments, regardless of the amount, if they identify the activity as suspicious. Since Ms. Redmond discovered counterfeit bills, she must file a SAR. However, as she does not suspect any particular individual, she does not need to name anyone specifically.
In this scenario, because the total amount of counterfeit funds discovered by Ms. Redmond is less than $25,000 and there is no indication of criminal activity by any employee or customer, there is no requirement to file a Suspicious Activity Report (SAR). SARs are typically required for transactions involving $5,000 or more in funds suspected to be derived from illegal activities. However, if there were any suspicion of illegal activity or involvement of specific individuals, a SAR might be necessary. But in this case, with no such suspicion, filing a SAR is not required.