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#2243010 - 09/23/20 10:22 PM SAR Ongoing Review
Anonymous
Unregistered

In March a report was filed for possible structuring. A follow up review was conducted in July, but no report was generated since the cash withdrawals had decreased. For the July review (3 1/2 months) the withdrawals ranged from $500 to $2,500, for a total of $12,000. The cash activity started increasing in August, ranging from $1,000 to $5,000, for a total of $30,000. The average has been about $2,500 per week. We noticed this on 9/1/20. Since we have noticed the increase should we file now or wait until 90 days after the last review?

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#2243015 - 09/24/20 03:55 AM Re: SAR Ongoing Review Anonymous
BrianC Online
Power Poster
BrianC
Joined: Nov 2004
Posts: 6,694
Illinois
Since you are beyond the 90-day period of the initial SAR filing, your next SAR will also be listed as an initial report since there was a break in the suspicious activity. You should refernce the March SAR in the narrative the next SAR.

Your filing deadline is 30 days from the date you identified the new activity as suspicious (9/1/20) so file this SAR by 9/30/20.
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#2243065 - 09/24/20 05:17 PM Re: SAR Ongoing Review Anonymous
Anonymous
Unregistered

The activity is the same activity we reported on the first SAR, the volume was just lower when we did not report? We have filed such updates before with no concern from regulators. This is why we need to review every 90 days for a year.

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#2243066 - 09/24/20 05:19 PM Re: SAR Ongoing Review Anonymous
praBSA Offline
Gold Star
Joined: Aug 2018
Posts: 348
If you believe it to now be suspicious, your filing is due by 9/30. This is new activity and an initial filing. Why do you review every 90 days for a year? That seems quite excessive smile

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#2243081 - 09/24/20 08:14 PM Re: SAR Ongoing Review Anonymous
SmallBankBSA Offline
100 Club
Joined: May 2018
Posts: 232
To OP, do you review every 90 days because they are now considered high risk?

In my system once I file a SAR the customer is bumped to high risk, Once we stop filing if the activity ceased, they are still considered high risk and the activity is monitored for a year. If no new activity is identified then the high risk flag comes off their account after a year. Our system does it automatically.

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