Skip to content
BOL Conferences
Thread Options
#2215378 - 06/11/19 02:53 AM continuing SAR
danyielg Offline
Gold Star
danyielg
Joined: Jun 2007
Posts: 437
OK
I filed a SAR last month for "transactions out of pattern" and "structuring". This customer had no apparent reason to have random cash deposits. Well......low and behold, this person is an acquaintance of an employee and board member. In daily conversations it has come to light that this person is gambling and apparently winning. So, now that I have this knowledge, how long do I have to file continuing SARs? Or is it still suspicious activity?

Return to Top
BSA/AML/CIP/OFAC Forum
#2215380 - 06/11/19 03:16 AM Re: continuing SAR danyielg
JacF Offline

Power Poster
Joined: Nov 2001
Posts: 6,719
PA
You have new information that you didn't have for your initial filing. When this SAR comes up for its 90 day review, you'll include this information in your analysis and make a determination, based on the entirety of the information, if a SAR is still warranted.

That said, it is also reasonable to ask if you should have had this information when you first reviewed the customer's activity. Was there a point where someone could have (should have) inquired about the source of the customer's cash deposits and provided that information to the BSA area?

Return to Top
#2215395 - 06/11/19 02:33 PM Re: continuing SAR JacF
danyielg Offline
Gold Star
danyielg
Joined: Jun 2007
Posts: 437
OK
Thank you JacPCB!

Return to Top

Moderator:  Andy_Z