If you have automated monitoring systems in place which results in alerts for review to determine if a SAR should be filed, is there really a need to have a separate tickler file of customers with prior SARs filed to be reviewed manually after 90 days of the initial SAR filing?

Example: January a SAR is filed for structuring due to an alert based on automated monitoring tools. That same tool is run each month. If the customer's activity in the future months does not result in an alert, is there really a need to manually review the customer activity to determine if the same activity is still ocurring?

Reminder - continuous activity SARs are for the the same type of activity. If different activity is identified via other monitoring tools, that would be considered a new SAR, not a continuing activity SAR (as per SAR Activity review April 2005).

I do both. I've had clients with prior SARs who beat the computer but I caught them in the manual review. They are subject to greater scrutiny and for me that means I look at them.

Exactly as Greg said...they may not necessarily hit your alerts, but that doesn't mean the activity has ceased. They could merely be skirting around the parameters of your rules, such as doing the same amount just spread out over a longer period of time, or slightly lower amounts than before, etc.

I'd conduct a manual review just to CYA, if you have the ability just filter their activity by transaction type (i.e. cash deposit), and that way you're able to quickly skim them to see if the activity has truly stopped.

Thanks Greg and Prime Time.

Anyone else? Same opinion as Greg and Prime Time or differing thoughts?

I am just wondering if it is really a futile exercise. How many of these manual reviews will result in a continuing activity SAR because the pattern changed just enough to be under the automated monitoring thresholds?

But I do see that it COULD happen.

I welcome any other thoughts, comments, opinions. Thanks.

We also do a manual 90-day review to ensure any further reportable activity hasn't slipped under our AML software radar.

Thanks Cape Codder.

Depending on the system you are using, you can see past SAR filings when viewing the customer record. If they have been filed on in the last three months, the alert clearing comment is "within 90 day SAR review period" and you close the alert and move on. You don't waste anytime analyzing. As others indicated, you use your past filed SARs as your tickler for 90 reviews - not your alert system.

Those alerts, though, can point to things you'd better include in your review. Perhaps you can go back to them to make sure you didn't miss anything.

Well, if you have AML software and you are not thoroughly reviewing any and all recent results on a specific customer prior to actually filing any SAR, you aren't using the software to its fullest potential

Wow! You'll need some popcorn and a Coke to do this soap opera justice...it should have had a thread of its own.

Anyone who tells the bank point blank that they are leaving because of operational weaknesses has my respect. However, copying the regulator diminishes it.

I'm going to guess that there is more to soap opera than we know.

Yikes

It is sad to see this play out in the media.

So, let's see if I got this right. JPM was cited for deficiencies, 30 of the 50 managers have left or been forced out since then, they call it a bloodletting, one left to "protect my professional reputation."

So, I work for a defective organization and now that they are trying to fix the problem of which I was a member, I am going to leave to protect my reputation?

It sounds like saying on your resume that, yes, I was an auditor at Enron, but I knew they had a problem but nobody would listen to me. So when they went bankrupt I lost my job, so please hire me next.

Maybe if you want to protect your reputation you should have left a long time ago.

It is a soap opera, but the media seldom reports the right story.