I am trying to get my upper management to make a decision concerning how to handle repeat SAR filings for structured activity. We do not have a set policy and have been advised by our external auditors that regulators may begin to insist on a policy that also includes account closure for repeat activity and SAR filings.
At the last bank I worked at, we mailed a letter after the first filing - the letter did not accuse them but it explained what structuring is and why it is a federal offense. We also included a booklet concerning CTRs for them to read. The BSA Officer manned all questions (quite a stressful job to endure).
I have some customers here who now have had seven SARs! A higher up finally asked me (after I had previously mentioned it but had gotten no help) what we could do. I know the BSA Officer is supposed to have the final say so concerning things, including this one. At this small bank, it has taken me two years to gain credibility to where my voice is heard.
Please take this poll to help me take back several recommendations to my committee.
ALSO, if anyone has a letter that you mail that you would be willing to share, please contact me personally and I would love to use it to develop my own, if that is the direction we take.