For any SARs that I do not file, I keep them in a file together. Right now I review those SARs not filed every 90 days and type up a new memo of why I am not filing again. Do I need to review each of those SARs not filed every 90 days as I do for my SARs that I do file? At what point would I stop reviewing them?

Hello Jwood89. May I ask why you review No SAR filings every 90 days? There is no requirement that you need to review your No SAR filings every 90 days - only those that you filed a SAR for. If they trip one of your monitoring reports for a transaction, then you would be reviewing their activity again.

UNLESS, in your decision you said you would monitor at 90 days. Then you have committed to reviewing. I would only recommend that for particular situation where you are on the fence about filing and want to see if the activity happens again.

I don't see a need to continuously review those items. If you see new activity on a previously reviewed customer, it would be appropriate to reference your prior research in making a determination to file or not file on the new activity. But a wholesale review of the reviewed-but-not-filed file is probably counterproductive.

If you do not file a SAR, then there is no reason to review at all. You do need to keep them for the required period for retention because auditors and examiners will ask to see them.

But see my caveat re if the bank said in their original memo that they would follow up. If they did they committed to do it but should stop doing that except in cases where they specifically wish to look again in 90 days to see if activity continued (for example).

Ok thank you. This helps me a lot!