Are credit unions required to file a SAR for a robbery if it has been reported to local law enforcement?

Credit unions, like other financial institutions, are not required to file a Suspicious Activity Report (SAR) for every incident reported to law enforcement, including robberies. The Bank Secrecy Act emphasizes that a SAR must be filed when a financial institution suspects that a transaction may involve funds derived from illegal activities or attempts to disguise such funds.

When a robbery occurs, although it is a serious crime that should be reported to the police, the decision to file a SAR is based on the circumstances surrounding the incident and the discretion of the financial institution. If the robbery does not present suspicious activity beyond the crime itself, and there are no significant indicators of money laundering or other illicit activities associated with that event, the credit union may determine that filing a SAR is not necessary.

Other factors around the robbery, such as if cash was stolen, whether a member was harmed, or if there are other suspicious activities or patterns related to the member or transaction history, could influence this decision, but they do not automatically necessitate a SAR just by the fact that a robbery was reported. This context highlights the importance of judgment and evaluation of the specific circumstances when determining if a SAR is warranted.