We filed a SAR for structuring cash deposits and it is now time to file a 90 day follow up. The cash deposit activity actually stopped following the first SAR however the customer is now structuring cash withdrawals. Is this a follow up or do we file a new SAR? Thank you.

We always file a follow-up SAR in cases such as this, even where there is a break, because I believe it is important to show the overall amount and date range in boxes 33 and 34. I know that there have been many threads in BOL saying that a new SAR should be filed but I think this gives an incomplete picture of the customer's structuring. We have never been criticized for filing in this manner.

Structuring cash-ins and structuring cash-outs are often two sides to the same coin (scheme). I think these are so related as to require they be connected in a SAR series.

I would consider this to be a follow up SAR as well.

Definitely a follow up. Doesn't matter what method was used to trigger a SAR. If (any) suspicious activity emerges within the 90-day time frame, continue the filing.

The original post was for activity after the 90 day f/u period for the initial SAR.