We're debating on how to properly handle additional accounts requiring review for the same client, after a SAR has been filed.

For example, let's say that a SAR was filed for structuring on account 1234 belonging to John Doe on 1/30/16. Account 3456 belonging to John Doe AND Jane Doe is prompted by the automated system for review on 2/15/16.

The question: Do you hold off on account 3456 to review it together with account 1234 during the supplemental review, or treat it as an independent investigation, ultimately leading to its own SAR?

How are other FIs handling this?

Anyone? Any feedback would be appreciated.

If subsequent transactions are conducted of the same activity type that we filed on previously, even if the activity involves additional accounts, we include it in the supplemental review. If the activity identified is new/different (e.g., filed for Structuring; now need to file for wire transfers), it's written up as a new case, with the usual 30-day deadline.

[quote=If the activity identified is new/different (e.g., filed for Structuring; now need to file for wire transfers), it's written up as a new case, with the usual 30-day deadline. [/quote]

Why can't the new/different activity be included in the supplemental review? By taking your method, it sounds like you can end up filing multiple parellel SARs for each transaction type for the same customer (e.g. separate SARs for cash, wire transfers, checks, etc.). What benefit does this add to the overall review, including the non-alerted transactions?

See FinCEN's The SAR Activity Review Issue 8, 2005.

https://www.fincen.gov/news_room/rp/files/sar_tti_08.pdf

"For situations where the nature of the activity reported changes after the original Suspicious Activity Report filing, the suspicious activity is no longer considered “ongoing”--e.g., the customer in the above example begins sending or receiving funds in addition to making structured withdrawals. In such cases, the institution should consider the changed activity a new transaction and should file a new Suspicious Activity Report within the normal filing deadlines, rather than updating a previous filing after 90 days. Because the activity is related, however, it may be appropriate to cross-reference any previously filed Suspicious Activity Reports in the narrative. Further, if previously reported activity ceases, no further Suspicious Activity Reports need to be filed."

Rather than filing multiple parallel SARs, you can combine structuring with the new activity, but don't wait the 90 days from your previous filing. You have 30 days from identifying the new transaction pattern to file you SAR.

Thanks Brian. What about for additional accounts belonging to the same suspect alerted for the same type of activity reported in the original SAR? Do you add that account in the supplemental review or treat it on its own and file a separate SAR?

SARs are not limited to a specific account, they are tied to the suspects activity within the banking institution.