A customer came into the bank wanting to send a wire on 7/30/2019. The teller did not feel comfortable sending the wire this time and completed a suspicious transaction form and submitted it since this customer had sent several wires previously to the same individual and the teller had warned this customer each time before sending the wires that it could be a possible scam. The teller looked back through the customers transactions that same day 7/30/2019 on their account to find even more suspicious activity. The suspicious activity date or range of suspicious activity was reported on the form that was submitted for review to the BSA Officer from December 2018 to current 7/30/2019 by the teller. When completing the SAR for submission what date should you use for field 30 date or date range of suspicious activity for the report? Here again this suspicious activity report was just submitted to the BSA Officer on 7/30/2019 and the actual dates of activity range were from 12/2018 to 7/30/2019. I would say that you should put those dates but then that would be considered a late SAR filing. I was told that the dates you put in field 30 is what the examiners go by so using those dates it would be definitely a late SAR filing. So if the suspicious activity was just reported to the BSA Officer to investigate on 7/30/2019 would you be incorrect putting the 7/30/2019 date in the to and from fields and then explain the situation and the dates of suspicious activity in the SAR narrative or how should this be handled?? Thanks!!

Since you are just discovering the suspicious information, I would use the 12/2018 to 7/2019 dates because it only becomes suspicious when you determine you have enough information to make that call. I have had this in the past and it is not considered a late filing because you put in the date of determination which would be 7/30/2019.

Where do you put the date of determination of 7/30/2019? Should I put that in the SAR narrative portion??

Yes, you can. That is what I did so that I would stay within my timeframe for the filing of the SAR.