Based on what I read on FinCEN Guidance 2014-G001 on MRBs and Marijuana LIMITED SAR filing, I’m understanding this as FIs should file basically letting FinCEN know that we have an MRB yet they are not violating any law or no suspicious activity has been identified.
So couple questions comes to mind:
1. If no suspicious activity is detected, then no dollar amount will be reported? And no date range?
2. In the narrative, do we just identify the business, related parties, address?
3. What boxes do we need to check on the SAR form? “Other” and type “Marijuana Limited SAR”?
4. If we start filing a Limited SAR and continue the relationship, then do we forever continue to filing Limited SAR (if nothing changes)?