Are credit unions required to file a SAR for a robbery that is reported to the local authorities?

In the context of BSA compliance, credit unions are not required to file a Suspicious Activity Report (SAR) specifically for a robbery reported to local authorities. The rationale behind this is that the BSA and its implementing regulations do not mandate SAR filings solely based on the occurrence of a robbery. Instead, SARs are required when there is suspicion of illicit activity concerning funds or transactions that could involve money laundering or other financial crime.

While certain circumstances, such as the presence of suspicious elements during a robbery or indications that the robbery may be part of a larger pattern of criminal activity, could warrant a SAR filing, the mere reporting of a robbery to law enforcement does not automatically trigger this requirement. Credit unions must make a judgment call based on the specifics of the incident and any additional suspicious activity that may be present. Hence, filing a SAR is not mandatory unless there are grounds to believe that additional suspicious activity related to money laundering or fraud exists.