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#1921425 - 05/08/14 06:15 PM SAR - Continuing or New?
Juby Offline
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Joined: Jul 2009
Posts: 218
A SAR was filed on one individual for check fraud. It has not yet been 90 days since that filing. Another situation occurred where a second individual committed check fraud involving an item from the first person's closed account. We do not know if they are in a relationship, but they must know each other due to the circumstances. Do you think we should wait until 90 days after the first SAR and include all this in a continuing activity report? Or file a new separate report on the second individual now and reference the other SAR?

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#1921431 - 05/08/14 06:27 PM Re: SAR - Continuing or New? Juby
Matt_B Offline
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Matt_B
Joined: Sep 2011
Posts: 1,648
A CU, Where Regs Don't Apply
Brand new report as you have a new suspicious person to report on. I would reference the other report in the description, however this is a totally separate situation/person that just happens to involve a check from the account of another suspicious person you've previously filed on.
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#1921459 - 05/08/14 07:06 PM Re: SAR - Continuing or New? Juby
Juby Offline
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Joined: Jul 2009
Posts: 218
Thanks for the input.

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#1921756 - 05/09/14 03:24 PM Re: SAR - Continuing or New? Juby
kw004h Offline
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Joined: Nov 2009
Posts: 219
Chicagoland, IL
I'll play devil's advocate and suggest that if you truly believe "they must know each other due to the circumstances" you could file your next SAR within 30 days of the new information, and it could still be a continuing activity SAR with the new suspect information added to the old one, and the activity amounts combined. There's no need to wait a full 90 days to file a continuing activity report, though.

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#1921806 - 05/09/14 04:36 PM Re: SAR - Continuing or New? Juby
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
I agree with kw004h's opinion.

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#2030188 - 07/28/15 05:16 PM Re: SAR - Continuing or New? Juby
New Manager Offline
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Joined: Jan 2004
Posts: 136
How about in the case of a new activity identified during the 90 day period?

We have a customer that was filed on for structuring and the 90 day review period if up at the end of September. But just this week we learned of possible check fraud. Would we wait until the 90 day period is up and report the new activity as part of the continuing SAR (assuming the structuring continues), or do we file a new SAR now for the new activity and then do a continuing one in September for the structuring?

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#2030203 - 07/28/15 05:47 PM Re: SAR - Continuing or New? Juby
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,225
Galveston, TX
Well, considering that I at least would hope that the account was closed immediately, I would just file a final SAR now on the customer citing the new activity and referencing the other SARs.
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#2030216 - 07/28/15 06:01 PM Re: SAR - Continuing or New? Juby
New Manager Offline
100 Club
Joined: Jan 2004
Posts: 136
Yes, the branch mentioned closing the account. We just weren't sure how to go about the continuing SAR and the new activity. Thanks.

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