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#2029825 - 07/27/15 02:15 PM SAR to Report Account Closed
kjbabington Offline
100 Club
Joined: Jan 2006
Posts: 194
FL
The bank has filed several SARs on a customer and determined to close the relationship. In the last continual SAR I included that the relationship would be closed. The relationship was opened longer that the date I included in the last SAR. Should I filed one more continual SAR with an overview of the activity until it was closed and the closed date? During this last period the activity was not anything that would be considered suspicious.

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#2029829 - 07/27/15 02:19 PM Re: SAR to Report Account Closed kjbabington
BFrame Offline
Gold Star
BFrame
Joined: Nov 2011
Posts: 401
USA
Personally, I do not think I would create a SAR only to explain that the account is now closed, if there was no suspicious activity during that period.

In the last SAR you filed, you indicated that the account relationship would be closed (at some point in the future), I don't see how saying "We closed it." would be very beneficial to law enforcement with no other activity to report.

But someone may disagree...
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#2029833 - 07/27/15 02:25 PM Re: SAR to Report Account Closed kjbabington
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
Originally Posted By kjbabington
Should I filed one more continual SAR with an overview of the activity until it was closed and the closed date? During this last period the activity was not anything that would be considered suspicious.

I think you've answered your own question. Since there is no activity in the review period that you determine to be reportable, there is no need to report. It is appropriate to note in the file that the review was completed and that no further suspicious activity was found.

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