I don't recall seeing this come up in the past, and I just wanted to verify my thinking. If we detect an MSB that has not registered with FinCEN, we file a SAR on them and require that they get registered, stop the activity (usually cashing checks) or close the account. If we find that an MSB has let their registration lapse, no question that we make them re-register, but would anyone think that we should then file on them? My thinking is not unless it appeared that this was caused by more than an oversight, but I wanted to get other opinions. Thanks for any thoughts.

It would depend. If the MSB forgot and filed right away, I wouldn't file a SAR. We have a process where we notify all of the branches when the MSB will expire (prior to the expiration date) and we obtain a copy of the MSB application in file so we know it's in the process and we follow up by the next analysis review.

Agreed, it could very well be an honest mistake and if they are going to refile then it's just a waste of time for you and the Fed if you file a SAR.

Talk to your customer. If they don't want to update their registration ASAP then you would simply close the account and file a SAR.

I agree with SAR Queen.

We've never had to do this. Is there a dollar threshold? What box in part III would be checked for type of suspicious activity?

An unregistered MSB is a violation of Federal law. How could you not file a SAR, regardless of the circumstances??