We are having a discussion about multiple SAR filings and how to go about closing the accounts.
I know we will have to have a policy that outlines what plan to do once a decision is made.

what is everyone's policy/opinion on this issue? for structuring SARs.

2 SARs for structuring - send customer letter with FinCEN brochure? (certified mail)
have the officer speak with customer about the FinCEN brochure?

next SAR after letter/brochure is received close the account?

what about other suspicious activity other than structuring?

thoughts please....

Our policy states 3 SAR filings and account get closed.
Tellers are advised to hand out the brochure after the first structuring, if they have not done so already.
It is part of their procedures.

Other activity...
It depends on the activity.
Some are closed immediately.

For structuring at the filing of the intial activity we have branch staff usually management provide the customer with the CTR brochure and strongly suggest they read it. If the activity continues by the next SAR we sit down with our ad hoc "committee" BSA Officer, Compliance Officer, Senior Management who oversees our department, and determine whether this is an account we would like to keep or not. We follow the same process for any other repeat filings just minus the CTR brochure. There have been times where we think maybe the customer just doesnt understand so I have completed a business call with the servicing branch managaer to personally deliver the brochure and answer any questions.