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#1508246 - 02/10/11 07:46 PM SAR Question
mkp122 Online
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Joined: Aug 2005
Posts: 211
NJ
We filed four SARs on a customer for money laundering and decided to terminate the relationship after the last SAR Filing. Should I file a final SAR stating that the bank closed the account even though there was no new suspicious activity?

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#1508410 - 02/10/11 09:38 PM Re: SAR Question mkp122
Deena Offline
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Deena
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PA
I think I would amend the last one you filed and check the account closed box and add a sentence to the narrative. Others may have different ideas.
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#1508436 - 02/10/11 09:56 PM Re: SAR Question Deena
devsfan Offline
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Joined: Jun 2004
Posts: 1,927
NYC
I would neither file a new SAR nor amend the last SAR; the suspicious activity is not continuing.

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#1508441 - 02/10/11 09:58 PM Re: SAR Question devsfan
Deena Offline
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Deena
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PA
I wouldn't be filing it due to the continuation of the suspicious activity (that's why I wouldn't file a new SAR), but I would amend the last one just to tie the loose end.
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Opinions expressed are mine and not necessarily those of my employer.

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#1508451 - 02/10/11 10:06 PM Re: SAR Question Deena
ACBbank Offline
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ACBbank
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New York City
I have heard stories of auditors and possibly examiners recommending filing a "final SAR." It's not required and I agree with Devs in there is no reason to file a "final SAR" or amend your previously filed SAR.
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#1508453 - 02/10/11 10:11 PM Re: SAR Question ACBbank
Deena Offline
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Deena
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I agree there's no requirement to do so and that's why I said others may have different ideas. I just said what I would do.
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Opinions expressed are mine and not necessarily those of my employer.

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#1508560 - 02/11/11 01:27 PM Re: SAR Question Deena
Pat Patriot Act Offline
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Joined: Apr 2009
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It's definitely voluntary, so I wouldn't make a habit out of it. If my institution felt the need to contact LE about the activity, then I would provide the updated information. Also, I'd wait until all of the close-out items (final checks, bank check, etc.) clear and note what institution/location and account# it appeared to be negotiated at.
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#1508611 - 02/11/11 02:11 PM Re: SAR Question Pat Patriot Act
dickr Offline
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dickr
Joined: Feb 2010
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Middlesex Cty NJ
All I've ever done is a memo to file in the SAR file as to why no SAR was filed.
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#1508976 - 02/11/11 05:26 PM Re: SAR Question mkp122
huezoslb Offline
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Joined: Aug 2010
Posts: 113
Long Beach, CA
Originally Posted By: mkp122
We filed four SARs on a customer for money laundering and decided to terminate the relationship after the last SAR Filing. Should I file a final SAR stating that the bank closed the account even though there was no new suspicious activity?


No reason to ammend the last SAR or refile a new SAR. Simply note in your file or note in your internal summary document that a SAR was not filed for the following reasons:
A-
B-
C-

I've also heard from some Auditors and Regulators to file a final SAR even when there's no suspicious activity. That's absolutely absurd and ridiculous.

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#1508987 - 02/11/11 05:29 PM Re: SAR Question huezoslb
Kathleen O. Blanchard Offline

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Kathleen O. Blanchard
Joined: Dec 2000
Posts: 21,281
The only time I ever did a "final SAR" (sounds ominous) was if we had activity to report and were also saying "we are kicking the customer out".
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#1509211 - 02/11/11 07:30 PM Re: SAR Question Kathleen O. Blanchard
Data Offline
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Data
Joined: Oct 2002
Posts: 226
Houston
I think it depends on the nature of the SAR. Do you think Law Enforcement will take it further? I got a request to keep an account open one time. We had closed the account after we filed the SAR. Law enforcement told me it would have saved them some time if they knew the account was closed.
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#1509271 - 02/11/11 08:03 PM Re: SAR Question Data
mkp122 Online
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Joined: Aug 2005
Posts: 211
NJ
We never heard anything from Law Enforcement that they were investigating the customer. I'm going to make a memo to the file that we closed the account. Thanks for everyone's thoughts.

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