We currently do not file hardly any SARs, but have seen in the last year, where the frequency is increasing at our bank. Just wondering what others are doing for filing on what amounts. Thanks for your input!

I suggest you file SAR's using the thresholds established by both BSA and regulations promulgated by your federal functional regulatory agency. Otherwise, your regulator is likely to critique your training.

Filing below the thresholds is largely a waste of time and should be under circumstances where there is some compelling argument for doing so. "Suspected terrorist financing" is the only reason I can think of.

I agree. I find banks many times that file SARs on small amounts are not only wasting resources, but also are totally missing the bigger picture. It leads me to believe that some of the four pillars are missing....... Those turn out to be very difficult audits for everyone involved. There is plenty to do in managing an effective BSA/AML program without creating make work.

We have also seen an uptick in filing, but they are almost always structuring related. When they have a couple of deposits in, it's usually over the $5K threshold, so SAR is required.

Generally, we go by the regs; however, we have occasionally filed voluntarily for activity that we feel would be useful for law enforcement. To add to Ken's list, some of the lower-dollar filings could also include some of FATFs human trafficking typologies (e.g. excessive backpage ad purchases). I'm sure there are other situations beyond those which could be compelling, but don't make a habit out of filing when it's not required.