AML SAR - how are they treated by the receiving institution?

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gnud

Entrepreneur
I've had to explain certain transfers in my account to my bank, the source of the money and the identity of the recipient and reasons for the transactions.
The source of the money was an account that I hold abroad and declare every year. Money coming to that account were a salary from my local business / its local other bank account. All of which is totally legal and declared.
I explained everything, supported by documents, yet I was unsure about how would transactions to my Wise account from the foreign account be viewed by the local investigating authority. So I deleted them from the foreign bank account statement's pdf file ... moreover I'm worried about transactions to my foreign company that were done from the foreign account months ago and are in statements from that period.

Am I in trouble? Will they detect it? Will the investigating authority take a look and thoroughly review all the information in the SAR that my bank will send them or will it simply remain on file when the case is already explained?
 

NicolasMaduro

Entrepreneur
I could imagine less than 1% of AML SAR reports gets looked at. I am a bit confused as to why you forged a document, when you say everything is declared? Whats the point of that.
 

Sols

Staff member
Mentor Group Gold
Am I in trouble?
Not yet.

Will they detect it?
It depends on whether they are convinced by what you sent (which depends on how good of a job you did manipulating the document) and whether they will still ask more questions.

Will the investigating authority take a look and thoroughly review all the information in the SAR that my bank will send them or will it simply remain on file when the case is already explained?
The life cycle of a SAR is hard to predict. If one is filed, it first goes to the senior AML Officer (MLRO/MLCO) of the company filing it, which then passes it to the relevant regulator. Depending on how busy that regulator is, they may or may not look at the SAR. But regardless, the SAR is archived and can be referenced in the future if more come in about you or anyone else involved in the suspicious activity.
 

gnud

Entrepreneur
I could imagine less than 1% of AML SAR reports gets looked at. I am a bit confused as to why you forged a document, when you say everything is declared? Whats the point of that.

The point is that I don't want them to know about my Wise account which, being an EMI, may attract a more thorough investigation of place of effective management of my companies, tax residency etc. Even though the arrangement is legal, since I spend time in both countries, there's a risk the local tax authorities may decide to appropriate the foreign company for taxation, and I want to mitigate that.
 
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