Due to the risk factors (previous sar), the review of this account should require enhanced scrutiny. Meaning, regulators would expect you to conduct an adequate 90 review and document your process as you would to any other high risk customer.
In our case, we have a word template that is utilize to document all inflow and outflow activities, communication with staff and/or customers (if any), etc... The more you document your conclusion not to file the less scrutinity you would face.
Keep in mind, that for consistency, this process should be addressed in your P&P.
[b]"Common sense is not so common." Voltaire~[u]