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#2224288 - 10/23/19 08:44 PM Amended or Continuing SAR??
Sunshine Offline
New Poster
Joined: Sep 2013
Posts: 18
Last month I filed a SAR on a customer for possible structuring. Since then we have new information on the situation and no longer believe that this person was structuring. The customer is somewhat challenged, for lack of a better term. He can take care of himself, hold a job, etc but does not have the best judgement skills. The customer came in today to add his sister to his account so she can help him as she found out he gave his SSN out to someone over the phone. While he was here our CSR asked him about the cash that he withdrew from his account. He told our CSR that he wanted the money at home so he was withdrawing the money and taking it home to keep there. His sister convinced him that he needed to bring the money back to the bank so it would be more secure. To be honest, I don't believe he has any knowledge of CTR's or CTR filing requirements. To report to FinCEN that we no longer believe this was a structuring event, should I file an amended SAR or a continuing SAR to explain the situation? If it's an amended SAR would I uncheck all the boxes and remove the dollar amounts and then explain in the narrative?

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#2224290 - 10/23/19 08:51 PM Re: Amended or Continuing SAR?? Sunshine
BrianC Offline
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BrianC
Joined: Nov 2004
Posts: 6,240
Illinois
There is no such thing as an "un-SAR." Document your no-file decision for continuing activity and move on. You can't take a SAR back once its filed.
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#2224292 - 10/23/19 08:58 PM Re: Amended or Continuing SAR?? Sunshine
Sunshine Offline
New Poster
Joined: Sep 2013
Posts: 18
Thanks Brian.

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