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#2238616 - 06/24/20 07:45 PM Repeated SAR within 90 days?
chuckchuck Offline
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Joined: Apr 2018
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I filed a SAR on a customer a while back because this person was knowingly serving as a money mule.
This week I find that they are at it again, however this time they are helping facilitate some of the out of state Nigerian/unemployment fraud schemes against another state.
Typically I would wait until 90 day re-review, but given the attention these special cases have been getting (and the secret service is asking for these to be filed timely) should I file ANOTHER SAR on top of the one I just did a month ago? Should I just let it sit until the normal re-review date for this customer?

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#2238618 - 06/24/20 08:00 PM Re: Repeated SAR within 90 days? chuckchuck
SmallBankBSA Offline
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How far is "awhile back"? How much longer until the 90 day review period?
Or you could amend the previous SAR to include the newly discovered activity?

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#2238619 - 06/24/20 08:06 PM Re: Repeated SAR within 90 days? SmallBankBSA
chuckchuck Offline
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it was a month ago. I could do an amendment, hadn't done one of those in awhile tends to slip my mind. thanks

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#2238621 - 06/24/20 08:26 PM Re: Repeated SAR within 90 days? chuckchuck
rlcarey Offline
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You would not amend a previous SAR for new activity outside of the time period first reported.

Financial institutions may also file SARs on continuing activity earlier than the 120-day deadline if the institution believes the activity warrants earlier review by law enforcement.
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#2238622 - 06/24/20 08:34 PM Re: Repeated SAR within 90 days? chuckchuck
edAudit Offline
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edAudit
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You are here
I filed a SAR on a customer a while back because this person was knowingly serving as a money mule.
This week I find that they are at it again, however this time they are helping facilitate some of the out of state Nigerian/unemployment fraud schemes against another state.

Why is this fraudster still a customer?
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#2238633 - 06/24/20 10:31 PM Re: Repeated SAR within 90 days? chuckchuck
RockChucker, CAMS Offline
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The Country
Great point Ed!
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#2238652 - 06/25/20 03:10 PM Re: Repeated SAR within 90 days? chuckchuck
HappyGilmore Offline
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Pulling people out of the ditc...
Originally Posted by chuckchuck
I filed a SAR on a customer a while back because this person was knowingly serving as a money mule.


why was the account not closed at the point you determined the customer was KNOWINGLY engaged in fraudulent activity?
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#2238657 - 06/25/20 04:04 PM Re: Repeated SAR within 90 days? chuckchuck
P*Q Offline

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My thoughts EXACTLY Happy, I'm like they are/were still a customer after round 1 why?

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#2238733 - 06/26/20 06:16 PM Re: Repeated SAR within 90 days? chuckchuck
Andy_Z Offline
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The first time a money mule is found, they may be a victim in the scheme, depending on the circumstances. But the second time, they're definitely part of the problem.
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