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#1667485 - 02/20/12 04:27 PM Followup SAR reporting
TomS Offline
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Joined: Jan 2004
Posts: 318
USA
I'm preparing a followup SAR to report ongoing cash structuring activity. When completing the SAR, what date range should be reported, the date range since the activity began or the date range since the filing of the previous SAR? Same question for the dollar amount involved in the transaction, should we report the total amount since the activity began, or the amount since the filing of the previous SAR?
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#1667488 - 02/20/12 05:15 PM Re: Followup SAR reporting TomS
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
The dollar amount and the date range should be cummulative; i.e. it should include the aggregate amount of all structured funds. The beginning date should be that listed on the first SAR and the ending date should be that of the last date covered by this SAR.

The new BSA - SAR allows for 2 amounts, the one covered by the current SAR and an aggregate amount.

I heard the leader of a SAR review team indicate that she sorts SARs for review by amounts, i.e. these eventually move to the top of the pile.
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#1667493 - 02/20/12 06:30 PM Re: Followup SAR reporting TomS
TomS Offline
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Joined: Jan 2004
Posts: 318
USA
Thanks, I appreciate the clarification.
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