My question is related to '90-day follow up SARs'. We do not bank marijuana businesses. If we find a company found a way into the Bank, we will close the account and file a SAR.
We do however, bank employees of these businesses (not the owners though). We would initially file a 'limited SAR' and watch the account for suspicious activity. If there is no suspicious activity during the 90-day period, would be be required to refile an updated "limited SAR"? I would say 'no' as the activity has not changed and no suspicious actity is occuring.
Thoughts?