Auditing SAR narratives
Month 1 - Filed SAR for structuring ($42,000)
Month 2 - Filed SAR for Transactions out of Pattern and Concerns as to Source of Funds ($230,000)
120 days from Month 1 - Filed SAR for Continuing Activity - Structuring $29,000 Entered $29,000 in Pt II line 23 and $71,000 on line 28.
120 days from Month 2 - Filed SAR for Continuing Activity - Transactions out of Pattern and Concerns as to Source of Fund ($81,000) - Line 23 $81,000 Line 28 $311,000
No where on the form or in the narrative for Month 2 or the two 120 day SARs is there any reference to the multiple SAR reasons and the aggravate amounts involved. BSA ops mgr. insists each is standalone but I would think at a minimum you would discuss it in the narrative.
Also, if you filed a SAR but the activity didn't continue during the 90 days but occurs again 6 month down the road I would think you'd should indicate in the narrative that previous SARs had been filed.