We have a customer, I'll call him Joe. In November 2004, Joe started completing transactions that we considered structuring so we filed a SAR. We then monitored the account for 90 days, however, Joe ceased structuring and we were all happy.
Fast forward to October 2005. Joe's at it again. We file a SAR, we monitor, he quits. We're happy. Sort of.
March 2006. Joe's being naughty again. We file a SAR, we monitor, he quits. We're happy. (See a pattern here?
Then, we had our S&S. The Fed guy said that because we kept the accounts open and that he had subsequently picked up his bad habits, we should have aggregated the totals in Part III box 34. He then referenced the SAR review on page 49 (of the pdf. Actual page 43 in the document).
"FinCEN often receives questions regarding how to provide supplemental information for suspicious activity that has already been reported previously on a SAR but is still occurring. The following guidance is provided..."
Now, in my opinion, it's the STILL occurring that is tripping me up. Joe ceased his activity and we were not required to refile the SAR within the initial 90 days of each SAR filing. So, to me, it wouldn't be STILL occurring but occurring again. I guess it's a matter of semantics but has anyone else heard of this?
Plus, if I'm going to aggregate totals from 2004, 2005, and the first one in 2006, would I also then have my date range from 2004 to today?
Sorry so drawn out. Thanks mightily for your patience!