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#2236342 - 05/07/20 07:58 PM Retention for SARs not filed
Susan Offline
Member
Joined: Mar 2018
Posts: 75
I recently attended a BSA course, and they said we should be retaining records for SARs not filed, in addition to SARs filed. They were not clear, however, about what should be kept. So I'm not sure if they meant potential SARs that were voted "no" by the SAR Committee, or cases that were investigated but closed as not suspicious and never made it to SAR Committee. What does your bank do?

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#2236346 - 05/07/20 08:17 PM Re: Retention for SARs not filed Susan
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 673
I keep the SARS not filed for the same amount of time as the SARS that were filed. Every month, I shred.
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#2236347 - 05/07/20 08:19 PM Re: Retention for SARs not filed Susan
Oursisnottoreasonwhy Offline
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Oursisnottoreasonwhy
Joined: Nov 2004
Posts: 503
Central Illinois
We keep all SAR info for all investigated cases for 5 years whether a SAR was filed or not.

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#2236361 - 05/07/20 09:38 PM Re: Retention for SARs not filed Susan
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,344
New York City
5 years as well.
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#2236369 - 05/08/20 12:42 PM Re: Retention for SARs not filed Susan
bcompliance Offline
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Joined: Sep 2014
Posts: 1,294
same here
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#2236371 - 05/08/20 12:51 PM Re: Retention for SARs not filed Susan
Skittles Offline
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Skittles
Joined: Sep 2002
Posts: 13,965
TN
ditto
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#2236382 - 05/08/20 02:16 PM Re: Retention for SARs not filed Susan
Goldrose Offline
Member
Joined: Sep 2018
Posts: 66
We consider 'No SARs' to be what you said- cases investigated but not filed, and possible SARs that went to committee and were voted no.

And when I say investigate I mean it looked like we might need to file a SAR based on the information we saw/was reported up front, not just a red flag you wanted to look into more to decide whether to start an investigation or not.

We would keep for 5 years as well.

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#2236383 - 05/08/20 02:18 PM Re: Retention for SARs not filed Susan
ColoradoAML Offline
Gold Star
Joined: Mar 2018
Posts: 338
I would recommend keeping both of the types of cases you described, whether non-filed by committee or before. If you were alerted that something might be suspicious, whether through a referral, manual process or automated system, you want to retain documentation for examiners to show them how you came to the decision not to file. How extensive that documentation is should probably be commensurate to how likely an examiner would be to question your decision.

Referral for a $100 bounced check - maybe a sentence saying it doesn't meet thresholds for investigation.
High-value customer depositing cash and wiring it to a tax haven and denied by the Committee - probably something fairly robust.

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