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#1076957 - 11/05/08 06:36 PM Recurring SARs
GoPirates Offline
Joined: May 2006
Posts: 59
Recently at a conference I attended the facilitator indicated that on recurring SARs, a cumulative amount should be used when referencing the total amount of the suspicious activity. For example, if the customer is being reported for continued structuring, the amount used should be the cumulative amount going back to the original SAR filed for that reason.

Is anyone else completing their SARs like that or do they treat each recurring SAR as it's own time period without considering the prior SAR activity?

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#1076972 - 11/05/08 06:44 PM Re: Recurring SARs GoPirates
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 39,544
Cape Cod
FinCEN wants the cumulative amount there, and the dates of activity on the supplemental SAR should start with the date range given in the first SAR in the series.

This excerpt from SAR Activity Review, Trends, Tips and Issues, Issue 4 (in BOL's free SAR Research Guide) may prove helpful to you:

John S. Burnett
Fighting for Compliance since 1976
Bankers' Threads User #8

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#1077030 - 11/05/08 07:24 PM Re: Recurring SARs John Burnett
Maytagman Offline
Gold Star
Joined: Jun 2008
Posts: 285
I do make the date range and dollar amount fields cumulative. Should suspect pages be cumulative too?

SAR 1 involves Joe, Moe, and Lowe. In the period since the first SAR's date range, activity has only involved Joe. Should my second SAR still list Moe and Lowe with their own subject (a.k.a. suspect) pages? If not, the cumulative dollar amount and date range doesn't seem to make sense because Joe didn't do all of it himself. What do others do?
"It is natural to give a clear view of the world after accepting the idea that it must be clear." - Albert Camus

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#1077120 - 11/05/08 08:21 PM Re: Recurring SARs Maytagman
WonderWoman Offline
Diamond Poster
Joined: Mar 2007
Posts: 2,108
gone fishin'
That is a great question Maytagman ... I do not necessarily make my suspects cumulative - but I will mention previous suspects in the narrative ...

I do not know if this is correct or not ... it would be interesting to hear what others are doing ...
My opinions are my own, and not that of my employer.

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