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#1320087 - 01/07/10 07:20 PM It happened over a year ago, Do i file a SAR now?
GottaLuvIt Offline
Junior Member
Joined: May 2009
Posts: 48
Upon reviewing our entire customer base for non resident aliens, i discovered a couple and therefore reviewed their transactions since the accounts were opened (I'm the new BSA Officer & previously this had not been done). One of these customers had structured cash deposit of $16,000. This happened five years ago. A SAR was not filed. Now that I have discovered it, do i need to file a SAR?

(the things i get myself into!!!!...)

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#1320123 - 01/07/10 07:31 PM Re: It happened over a year ago, Do i file a SAR now? GottaLuvIt
banker1976 Offline
Gold Star
Joined: Nov 2005
Posts: 346
Mid-Atlantic
Wow. You found a structured transaction from 5 years ago? Well, the SAR laws do state to file within 30 days from the date of detection. Though you might opt to not file a SAR, however, perhaps alternatively make a no-SAR filed file referencing the situation and your decision not to file based on the transaction occuring five years ago; provided current activity is not unusual or otherwise suspicious. I'm sure that $16,000 is long gone & non-traceable by now.
Last edited by banker1976; 01/07/10 07:33 PM.
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#1320579 - 01/08/10 01:28 AM Re: It happened over a year ago, Do i file a SAR now? GottaLuvIt
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Assuming there is some way that you can convince yourself that the transactions were structured, file the SAR.
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#1320653 - 01/08/10 01:46 PM Re: It happened over a year ago, Do i file a SAR now? Elwood P. Dowd
GottaLuvIt Offline
Junior Member
Joined: May 2009
Posts: 48
So in short, forget the date, if it ist determined to be structured, then file the SAR

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