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#2136049 - 06/27/17 05:14 PM continuation SAR threshold?
SUSA Offline
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SUSA
Joined: Nov 2011
Posts: 400
USA
Good afternoon.
Is there a threshold to file a continuation SAR?
I understand that if a subject is known, we must file a SAR if the activity reaches the $5k mark.
Does the same apply to the 90 day review period after the initial SAR? Or does any amount of continuing activity warrant a follow-up SAR?

Example: Customer was kiting & a SAR was filed for the activity. In the 90-day review period, the kiting occurred only one additional time & did not reach $5k in that time period. Do I have to file an additional SAR for this new amount?

Thanks for your time.
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#2136160 - 06/28/17 11:47 AM Re: continuation SAR threshold? SUSA
Elwood P. Dowd Offline
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Elwood P. Dowd
Joined: Aug 2001
Posts: 21,939
Next to Harvey
Each continuation SAR must meet the threshold requirements during the period covered before it would be classified as mandatory. If the activity continues, but the threshold is not met, you would write a file memorandum explaining why no SAR was filed.

With kiting, the bank's most critical task is closing the account, not filing the second SAR.
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#2136269 - 06/28/17 05:16 PM Re: continuation SAR threshold? SUSA
SUSA Offline
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SUSA
Joined: Nov 2011
Posts: 400
USA
Thanks Ken.
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