Skip to content
BOL Conferences
Thread Options
#1910964 - 04/02/14 06:46 PM Initial / Continuing?
BSAAnonymous Offline
100 Club
Joined: Feb 2012
Posts: 165
We file a SAR on a customer for structuring in their personal account (initial SAR). After the SAR is filed, a month later, customer starts structuring in their business account. Wait for the supplemental review and check off continuing on the SAR or is this an initial because customer is structuring in a different account? Thoughts?

Return to Top
BSA/AML/CIP/OFAC Forum
#1910981 - 04/02/14 07:07 PM Re: Initial / Continuing? BSAAnonymous
John Burnett Offline
10K Club
John Burnett
Joined: Oct 2000
Posts: 40,086
Cape Cod
This is my opinion only -- individuals structure transactions; businesses don't. Your said that the business is owned by the individual, right? I'd broaden my ongoing review scope to include both accounts (and any other accounts owned by the individual or the individual's businesses) and wrap the whole thing into the next continuing SAR for the individual, adding information on the other accounts he/she appears to have been using for structuring.
_________________________
John S. Burnett
BankersOnline.com
Fighting for Compliance since 1976
Bankers' Threads User #8

Return to Top
#1911043 - 04/02/14 08:31 PM Re: Initial / Continuing? BSAAnonymous
AquaMarine Offline
100 Club
Joined: Jun 2011
Posts: 156
New York, NY
I second John's suggestion. There is no need to file separate SARs if both accounts have common ownership. Wait for the supplemental review period and pack them together.
_________________________
"Give thanks in all circumstances; for this is God's will for you in Christ Jesus." -Thessalonians 5:18


Return to Top
#1911066 - 04/02/14 09:04 PM Re: Initial / Continuing? BSAAnonymous
devsfan Offline
Diamond Poster
Joined: Jun 2004
Posts: 1,927
NYC
I absolutely agree with John; people do it businesses do not.

Return to Top

Moderator:  Andy_Z