Antoher scenario. We get the need for the detection date and have some new procedures in place.

Our auditors go to extremes when reviewing transactions during their BSA audit. Fine. been that way for years. This time they went back to April to review trans. and found that a businessman and his secretary each transacted $9000 on the same day from the business account. OK. We would never have detected that one using current systems. Months later, however, our AML software did come up with a similar transaction for which we will file a SAR. Our question is, should we also go back in time, to include the audit findings and, also use, this as the date of detection?

Trees, it sounds as though you didn't feel this rose to the level of reporting as suspicious activity when Audit found it. Now that something similar has happened, I would re-consider the previous transactions and include them if you now feel they appear suspicious.

I've had situations where something that originally didn't appear suspicous, later appeared suspicious based on subsequent transactions.

We have had similar experiences. Sometimes I don't consider an isolated transaction suspicious; however, if over time a pattern starts to develop, I include past transactions and explain it in my narrative.

Thanks everyone. Sounds like a plan.