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#1984043 - 12/18/14 04:09 PM Activity no longer suspicious
Antilles Offline
100 Club
Antilles
Joined: Jan 2007
Posts: 227
Southern US
We are having a debate on SAR filings. If we have a customer that we have filed continuous activity SARs for and no the activity is stopped after an account is closed or we have determined that the reason for the activity is not suspicious do we need to file a "FINAL" SAR explaining that this is the last SAR or do we just stop filing SARs and document our internal files on why another continuous activity SAR was no filed?
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"Success is going from failure to failure without a loss of enthusiasm." - Sir Winston Churchill

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BSA/AML/CIP/OFAC Forum
#1984050 - 12/18/14 04:16 PM Re: Activity no longer suspicious Antilles
ACBbank Offline
Power Poster
ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
There is no such thing as a "FINAL" SAR. If the suspicious activity has stopped, you should document such during your review of the relationship and move on.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1984063 - 12/18/14 04:27 PM Re: Activity no longer suspicious Antilles
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,364
Galveston, TX
"the activity is stopped after an account is closed"

Well I surely hope so smile smile
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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