A SAR was filed on a customer for transactions that occured in June and July. We have received information that this customer is committing fraud and has additional transactions in September and October.

Can we file another SAR now including the September transactions? Since we have received information (from a reputable source) this customer is committing fraud does the 90 day timeline even apply?

Yes, you don't have to wait. If you have additional information that would aid law enforcement you should file sooner rather than later.

If the customer is committing fraud, I'd get that SAR out as soon as you can assemble the information, and give the customer the boot as soon as possible. You don't want any of the fraudulent actions of your customer coming back to involve the bank in a loss or risk of a besmirched reputation (for banking the SOB).

If you know that a law enforcement or federal agency is investigating them, after you file the updated SAR, you may wish to give them a call as well. .