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#1021157 - 08/15/08 04:20 PM Help with repeat SAR....
SARempress Offline
Junior Member
Joined: Jul 2006
Posts: 37
Deep in the Heart of Texas
Can someone share your policy on when you include information from a previous SAR in a new filing? I know if it's a 90 day update we would include from begining of suspcious activity through current date, but what about when there is a gap? For example, we filed a SAR on "Bob" a year ago for structuring and he's not done it again until now. Is this a "new" SAR or should we include dates/amounts from the last report?

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#1021248 - 08/15/08 05:17 PM Re: Help with repeat SAR.... SARempress
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
It would not be a "new" SAR. I always carry over dates & amounts.


In the Narrative I usually state something like.

Previous activity reported from XX/XX/XX to XX/XX/XX included: blah blah

Activity from XX/XX/XX to XX/XX/XX was not reported due to: blah blah

Current activity being reported from (you get the idea)
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#1021584 - 08/15/08 08:29 PM Re: Help with repeat SAR.... WonderWoman
smash Offline
Gold Star
Joined: May 2004
Posts: 331
Texas
I would consider it a new SAR. Last year's SAR was the initial report. 90 days later there was no followup SAR needed. That SAR process ended.

A year later, you now have a new SAR process started. If you want to be nice, I might stick in a single sentence in the narrative that states that this same activity was reported previously in a SAR on XX/XX/XXXX, but I would not aggregate dollar amounts and dates on page 2 of the SAR.

Heck. Leave some work for law enforcement!!

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#1021596 - 08/15/08 08:43 PM Re: Help with repeat SAR.... smash
WonderWoman Offline
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WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
Oh I don't agree. (just my opinion)

Aren't we all on the same team? If you have additional information - why not share it? Besides, I've noticed the higher the dollar amounts - the quicker the response from law enforcement.

Also, in my neck of the woods we have a lot of "seasonal" activity (if you know what I mean) ... so I get the same people doing the same activity - right around crop season. I like to tie that all together.
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#1021829 - 08/18/08 01:12 AM Re: Help with repeat SAR.... WonderWoman
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
We generally conducted a series of 90-day reviews following a SAR-able offense. Once I completed all reviews (generally 3 follow-up reviews) with no repeat activity identified, the case is closed. Once closed, another incident would trigger the opening of a new case. While I might mention the date of a prior SAR for a similar or related incident, I would not treat it as continuation of the pattern for date/dollar aggregation purposes.
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#1025249 - 08/21/08 05:34 PM Re: Help with repeat SAR.... BrendaC
murphysgirl Offline
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murphysgirl
Joined: Oct 2004
Posts: 269
Home of the Red Sox
Sorry to resurrect this but... we just had an auditor make us aggregate all the way back to the initial SAR on each person until the most recent even though there were gaps of more than 90 days between instances and send in corrections. Where can I find guidance on not aggregating after a cool off of 90 days?
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Humility about how little I know has encouraged me to listen more carefully and more wisely.
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#1025270 - 08/21/08 05:44 PM Re: Help with repeat SAR.... murphysgirl
WonderWoman Offline
Diamond Poster
WonderWoman
Joined: Mar 2007
Posts: 2,108
gone fishin'
I don't think you will ... from what I understand there is no guidance on this & we're required to carry over the dates/amounts.


But I could be wrong???
_________________________
My opinions are my own, and not that of my employer.

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#1025305 - 08/21/08 06:03 PM Re: Help with repeat SAR.... WonderWoman
murphysgirl Offline
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murphysgirl
Joined: Oct 2004
Posts: 269
Home of the Red Sox
OK I will go with the easiest thing and that is do what they say.
Thanks
_________________________
Humility about how little I know has encouraged me to listen more carefully and more wisely.
John Templeton


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