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#1862271 - 10/17/13 04:12 PM Continuing Acitivity or Correct/Amevd
Debbie123 Offline
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Joined: May 2009
Posts: 15
I have a SAR that was filed 8/3/12 and I am going to file another as of 10/16/13. Do I choose continuing activity, correct/amend or both?

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#1862275 - 10/17/13 04:25 PM Re: Continuing Acitivity or Correct/Amevd Debbie123
AMLMGR Offline
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Joined: Jan 2010
Posts: 35
Do you mean you filed the first SAR on 8/3/2013? If so, then you have to take a few things into account: Why are you filing another SAR? To correct information in the prior SAR? If so, then that is a corrected/amended. If you are filing to report additional activity within the new time frame, that's just a continuing activity report.

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#1862279 - 10/17/13 04:33 PM Re: Continuing Acitivity or Correct/Amevd Debbie123
Debbie123 Offline
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Joined: May 2009
Posts: 15
No they filed oo 8/3/2012 over a year ago. I just took over this position and discovered the need to file for ongoing activity. The suspicious actvity started in 2009 and the previous BSA officer did not notice the suspicious activity until 2012 and then only filed on a portion of it.

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#1862282 - 10/17/13 04:36 PM Re: Continuing Acitivity or Correct/Amevd Debbie123
Debbie123 Offline
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Joined: May 2009
Posts: 15
The portion reported was the outgoing cash for a couple of months in 2012. I will be reporting on all of the activity since 2009 to the present.

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#1862554 - 10/18/13 12:34 PM Re: Continuing Acitivity or Correct/Amevd Debbie123
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
You're going to report activity that took place over a four year period, but a portion of it was included in a previous SAR filed more than a year ago?

What would probably be most readily understood by your reader is an "initial report" that covers the entire period. In the beginning of the narrative, briefly note that a portion of the information that follows was reported in a SAR dated [XX/XX/XX] with a DCN of X. Note that this SAR incorporates the information it contained, but it is being filed to present a more comprehensive picture to law enforcement.

With more details regarding the activity, that suggestion might change...

Your regulator may want to critique the situation, but just look their representative in the eye and say, "I found it and I fixed it. Please note that if you mention it in the written report."
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