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#1056047 - 10/01/08 10:30 PM SAR
chicoca Offline
New Poster
Joined: Jul 2008
Posts: 1
If a SAR is completed for cash withdrawals that appear to be a structuring situation, and the member continues to withdraw cash, do we have to complete a SAR for every withdrawal with an ongoing aggregate of cash withdrawn?

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Operations Compliance
#1056068 - 10/01/08 11:37 PM Re: SAR chicoca
DebL Offline
Gold Star
Joined: Jan 2007
Posts: 314
CA
Just an FYI, you'd probably get more attention if you move this to the BSA forum.

If you file a SAR for structuring and the activity continues, you file another SAR within 90 days of the first filing and every 90 days thereafter. You don't need to file a new SAR each time they structure. Each update would aggregate the cash activity of the prior reports.

Now, if they engage in another suspicious activity (ie. kiting/mortgage fraud) you would file a new SAR on that and not wait for the 90 day update.
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