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#1522228 - 03/15/11 09:10 PM SAR Filing on a closed account
mrk Offline
New Poster
Joined: Mar 2007
Posts: 4
A receipt of a law enforcement inquiry prompted a review of an account that has been closed for over 3 years. If the account activity meets the SAR filing standards, should a SAR be filed on an account that has been closed for such a long period of time?

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BSA/AML/CIP/OFAC Forum
#1522249 - 03/15/11 09:48 PM Re: SAR Filing on a closed account mrk
huezoslb Offline
100 Club
Joined: Aug 2010
Posts: 113
Long Beach, CA
It depends on the scenario and amount. There's no right or wrong answer here.

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#1522372 - 03/16/11 01:54 PM Re: SAR Filing on a closed account huezoslb
BrendaC Offline
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BrendaC
Joined: Sep 2001
Posts: 6,029
Sweet Home AL
You felt it necessary to conduct a review of the closed account; therefore, if the information identified is SAR worthy, I would recommend filing.
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#1522455 - 03/16/11 04:00 PM Re: SAR Filing on a closed account BrendaC
BC78a Offline
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BC78a
Joined: May 2006
Posts: 311
New York
Be prepared for an examiner to ask why you did not catch the activity 3 years ago.
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