During a recent training course, I noted a discussion point that for Continuing Activity SARs, the date range field is expected to be the range of the 90-day review period and not necessarily the starting and ending date of when the suspicious activity within the review period occurred. We use a software that automatically completes these dates with the start date and end date of the activity pulled in as suspicious. I downloaded a current SAR discreet filing form from FinCEN and hovered over Field 30 to review the instructions. For Continuing Activity SARs, it states, "If 'Continued activity report' is selected as the filing type, enter only the date range covered by this SAR. Record in Part V the aggregated date range of all SARs filed on the continuing suspicious activity."

1. Does the fact that the first part of these instructions leaves out the word "’suspicious’ date range covered by this SAR" indicate that we are to input the 90-day review period range in Field 30 rather than the date period of when the suspicious activity occurred during the review period?

2. Is the narrative expected to list the range of first suspicious activity through the current activity date followed by the range of activity occurring for the current filing or do they just expect us to list the aggregate range of all activity without additional date clarification for the current filing?

3. Has anyone had comments from auditors or regulators concerning this?

I searched the forums, but I was unable to locate anything concerning these areas.

Thank you to anyone who can provide clarity!

I disagree with your trainers. Box 30 is for the date range of suspicious activity, not the entire review period, and the fact that it's a continuing review shouldn't change the meaning of the box.

The instructions say "If the FinCEN SAR involves continuing activity with box 1c "Continuing activity report" checked, enter only the date range covered by this FinCEN SAR." In my interpretation, that's instructing you not to include the activity from the previous review(s) that prompted this 90-day review, not instructing you to list the 90-day period.