When should a credit union file a Marijuana Termination SAR?

Filing a Marijuana Termination Suspicious Activity Report (SAR) is necessary when a member is terminated for reasons related to anti-money laundering compliance. This requirement stems from the need to monitor and report suspicious activities that may indicate the potential for money laundering or other financial crimes, particularly in industries linked to marijuana, which continue to face complex regulatory challenges.

In this context, if a credit union terminates a member specifically due to concerns that relate to complying with anti-money laundering regulations, it is essential to report such actions. This ensures that the activity is recorded in the financial institution's oversight processes, as it could be relevant for ongoing investigations or regulatory reviews.

While termination for other reasons, such as the expiration of a business license, the sale of the business, or changes in law, may prompt further evaluation of the situation, they do not inherently indicate suspicious activity as strongly as a termination due to anti-money laundering compliance issues. The focus in this case is on the heightened scrutiny required for members linked to the marijuana industry, highlighting compliance obligations under the Bank Secrecy Act.