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#484343 - 01/17/06 02:47 PM SAR monitoring indicator?
KYBanker Offline
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Joined: Jan 2005
Posts: 18
If a small community bank has not filed a SAR in over 2 years does that seem to be an indication of problematic monitoring procedures or is it reasonable that given a low risk area etc this may be possible? The Bank is utilizing the best practice transaction monitoring reports daily and training on suspicious activity has been given to all staff.
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#484344 - 01/17/06 06:54 PM Re: SAR monitoring indicator?
opsgal2 Offline
Member
Joined: Jul 2005
Posts: 82
Make sure you're documenting your decisions to NOT file, just like you would your decisions to file. The FFIEC manual says that the examiners are supposed to be focusing on the policies, procedures, and processes, not individual SAR filing decisions (unless it's a really bad decision )

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#484345 - 01/17/06 06:55 PM Re: SAR monitoring indicator?
AnonRegulator Offline
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Joined: Mar 2002
Posts: 451
Everywhere, USA
The lack of filing SARs doesn't in and of itself lead the vast majority of examiners to conclude that there is a problem. What it does do is tell the examiners that they have to ask some questions about the bank's level of knowledge about its customer base and BSA, its training program and risk profile, and do some transactional testing to verify that profile. So, it is possible that a low risk bank may not have had reason to file a SAR in over 2 years, but it's my experience that this is a rather exceptional situation. AR.

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