As an internal auditor, if you identify a transaction that you see as structuring (long time customer takes out $30,000 over a period of 4 days. 3 transactions in the high $9,000's). How do you handle the difference of opinion? BSA Officer does not believe it is SAR worthy. Seems to me we have filed SAR's for similar transactions in the past.

You document your recommendations and report to the board and the board and management decides whether to act. That's about all you can do.

I'd ask the BSA Officer why it wasn't before proceeding. Rather than state a SAR should have been filed, maybe the issue was that the transactions weren't identified and aggregated. Therefore the bank doesn't have a program for monitoring such transactions. Look at the bigger picture rather than (maybe) one instance.

The transaction was identified by the BSA department and they performed monitoring of the account. No other such activity was noted, so he stated that he believed it wasn't SAR worthy. No other explanation that that.

Am I off base on this one?

What explanation did they obtain from the customer that caused them to conclude the SAR was not warranted? If, as I would expect, the answer is "none," I would include a finding recommending the adoption of a (or adherence to an already adopted) policy requiring documentation of the SAR decision process.

My advice is to stay away from arguing about individual decisions - look at the process: is it reasonable? does it exist at all?

I think thats sound advice. Thanks