We have a situation where a SAR may be filed on ABC Corp for suspicious activity. A month later we plan to file a SAR on DEF LLC for suspicious activity. Both entities have common BO's, however due to the timing involved, separate SARs and reviews need to be conducted.
I may be mistaken in my old age, but I seem to recollect FinCEN opining that in such cases that it would be appropriate to group the filings together (Possibly in a SAR Activity Review). Does any one have a link to this to advisory? If not, am I flat out mistaken on this?
"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu