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#2139673 - 07/27/17 12:46 PM Multiple SARs filed for different reasons - 90 day
Jerseygirl Offline
Platinum Poster
Joined: Apr 2005
Posts: 684
Jersey Shore
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.

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#2139686 - 07/27/17 01:21 PM Re: Multiple SARs filed for different reasons - 90 day Jerseygirl
Daisy Doodle Offline
Diamond Poster
Joined: Feb 2014
Posts: 1,030
Southern U.S.
When I have this situation I bring them together as soon as possible so I don't have to keep up with two cycles.

For example I would say in my narrative, a SAR was filed in June for structuring, but in July we noted suspicious wires as well. Since the June SAR, two additional instances of structuring occurred as described below. And then discuss the wires.

Something like that. And yes, everything is cross-referenced to each other.

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#2139739 - 07/27/17 04:23 PM Re: Multiple SARs filed for different reasons - 90 day Jerseygirl
RockChucker, CAMS Offline
Diamond Poster
Joined: Jul 2013
Posts: 1,700
The Country
I also work my SARs like Daisy. My thought is that if there is multiple kinds of "fraud" or such I can select multiple things in the SAR that indicate the activity discovered. No reason to file separate SARs in most cases.
_________________________
A successful man is one who can lay a firm foundation with the bricks others have thrown at him.
-David Brinkley

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#2139748 - 07/27/17 04:36 PM Re: Multiple SARs filed for different reasons - 90 day Jerseygirl
bcompliance Offline
Diamond Poster
Joined: Sep 2014
Posts: 1,294
I also follow what the others have posted.
_________________________
CRCM, CAMS

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#2140371 - 08/01/17 05:21 PM Re: Multiple SARs filed for different reasons - 90 day Jerseygirl
E.E.G.B Offline
Power Poster
E.E.G.B
Joined: Jul 2002
Posts: 6,726
the sandy shore
Imagine how frustrating it would be for a law enforcement person to try to figure out just what is going on with that person / account, in the multiple individual SAR filing scenarios.

I also vote for the unified as soon as possible approach.
_________________________
I disbelieved what he was saying so hard, I probably created an alternate universe where it wasn't true.

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