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#1977536 - 11/19/14 06:51 PM Correcting SAR if transaction no longer suspicious
Anonymous
Unregistered

Without getting into too many details, after much research and internal debate over a situation with a borrower, we filed a SAR. We just found out today that the borrower provided documentation yesterday, along with proof from the IRS, that gives us enough comfort that the transaction truly was not suspicious. Had we known this information prior to Friday we would not have filed a SAR, just documented everything to support our decision not to file.

We're not sure now what to do. Can you even file an amended SAR to simply state you no longer believe the activity to be suspicious? Help would be appreciated, I have not run into this before.

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#1977555 - 11/19/14 07:38 PM Re: Correcting SAR if transaction no longer suspicious Anonymous
ACBbank Online
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ACBbank
Joined: Jul 2006
Posts: 3,959
New York City
That's a really good question. I don't believe you can amend a SAR to state that a transaction(s) is no longer considered to be suspicious. Maybe a guru can confirm or deny this?

I would simply conduct a write up stating that further documentation has been provided subsequent to the initial SAR filing and that the activity is no longer considered to be suspicious.
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#1977705 - 11/20/14 02:57 PM Re: Correcting SAR if transaction no longer suspicious Anonymous
MagicCity Offline

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MagicCity
Joined: Apr 2003
Posts: 3,003
Fort Lauderdale, Florida
We have done this in the past - i.e. filed a second SAR shortly after the first one to say it was incorrect, based on new information that came to us.
I think you have to do the second SAR to clear your customer's name if information that came to light after the SAR was filed shows that it was not suspicious.

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#1982576 - 12/11/14 07:37 PM Re: Correcting SAR if transaction no longer suspicious MagicCity
kw004h Offline
100 Club
Joined: Nov 2009
Posts: 219
Chicagoland, IL
Originally Posted By: MagicCity
I think you have to do the second SAR to clear your customer's name if information that came to light after the SAR was filed shows that it was not suspicious.



One should keep in mind that filing a second SAR does not "erase" the information about the filing from the government agency database. I'm not offering an opinion one way or the other about filing an amended SAR if the activity is no longer considered suspicious, but just commenting that "clearing the customer's name" may not actually be accomplished by doing so.

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#1982589 - 12/11/14 07:57 PM Re: Correcting SAR if transaction no longer suspicious Anonymous
Anonymous
Unregistered

Anon2 sez: Big agree with kw004h. And whoa, read the title of what you're filing: SUSPICIOUS activity report. You don't see a problem with informing the government, merely by filing the report, of your customer's inherently SUSPICIOUS activity, in an effort to advise that it is not suspicious? It won't correct your prior decision. It will make matters worse. Having 2 SARs filed on you in error is worse than having 1 SAR filed on you in error.

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