I am looking for a standard of how many multiple SARS you would file (BSA/structuring/money laundering SARs) before you close an account. I need to add this to my procedures but cannot find a standard to go by.

Can anyone share with me?

I don't believe you'll find any standard for this. It depends on the customer, what you know, what risk management is willing to take, etc. Maybe someone can give you some real life experiences, but I don't think there is any industry standard.

I agree with David, there is no industry standard nor is there a regulatory standard (see question 5 of the BSA FAQ's). I would encourage you not to back yourself into a corner by using a specific number in your procedures. There are many fact situations where you might spell out in the first SAR you file your plans for closing the account unless you recieve a timely, written request from law enforcement to keep it open.

The interagency guidance on MSBs actually indicates that banks should have a board approved policy on when accounts should be closed. However, my suggestion would be that policy should contain broad guidelines and give the security or BSA officer discretion in exercising that power.

I agree with David and Ken. It can be a difficult decision - especially when the customer has outstanding loans with your bank. If you don't think the customer is involved in illegal activity and your SAR is simply to report structuring, then consider "educating" your customer on the bank's reporting requirements related to CTRs. Many business owners are misinformed. Believe it or not, some CPAs tell their clients "never conduct a transaction with more than $10,000 in cash - or you will be audited!" Crazy, but true!

You might consider putting a section in your deposit agreement regarding "Cash Transactions." When you discover legit customers structuring, have them read the information. I think a company named Bank Security, Inc. sells a brochure that you can use - someone else correct me if I have the name of the company wrong.

Dolly, There is a brochure titled "FACTS YOU SHOULD KNOW" printed by National Association for Bank Security, www.banksecurity.com

It clearly explains currency reporting rerquirements and has a very good section in which it states that it is a criminal violation to ...

We have it in all branches and give it to our customers when we think it is appropriate.