I have a business customer I have been filing on for structuring cash deposits. Both owners of the business have been suspects and are conducting the cash deposits. Fast forward to this month where one owner of the business has been structuring withdrawals from her personal account, $9000 cash for five days in a row.

Would you file a new SAR on the withdrawal activity or include it with the continuing SAR which will need to be filed this month.
Thanks!

If I have reason to think they are connected activities, I'd file them together.

This would be new activity and require an Initial filing based on FinCEN guidance.

However, you can combine all activity into a single SAR, reference the prior SAR DCN in the narrative to connect them for law enforcement.

I agree. Structuring cash deposits and structuring cash withdrawals aren't necessarily connected behaviors. Unless you see a pattern suggesting the use of both structured deposits and structured withdrawals in possible money laundering, I'd start a new activity SAR and reference the older filing in the narrative.