Recently at a conference I attended the facilitator indicated that on recurring SARs, a cumulative amount should be used when referencing the total amount of the suspicious activity. For example, if the customer is being reported for continued structuring, the amount used should be the cumulative amount going back to the original SAR filed for that reason.

Is anyone else completing their SARs like that or do they treat each recurring SAR as it's own time period without considering the prior SAR activity?

FinCEN wants the cumulative amount there, and the dates of activity on the supplemental SAR should start with the date range given in the first SAR in the series.

This excerpt from SAR Activity Review, Trends, Tips and Issues, Issue 4 (in BOL's free SAR Research Guide) may prove helpful to you:

http://www.bankersonline.com/security/sar/sarongoing.html

I do make the date range and dollar amount fields cumulative. Should suspect pages be cumulative too?

SAR 1 involves Joe, Moe, and Lowe. In the period since the first SAR's date range, activity has only involved Joe. Should my second SAR still list Moe and Lowe with their own subject (a.k.a. suspect) pages? If not, the cumulative dollar amount and date range doesn't seem to make sense because Joe didn't do all of it himself. What do others do?

That is a great question Maytagman ... I do not necessarily make my suspects cumulative - but I will mention previous suspects in the narrative ...


I do not know if this is correct or not ... it would be interesting to hear what others are doing ...