Our BSA Officer is concerned about providing SAR's to the third party auditors we have hired to do our BSA Audit.

Is anyone aware of citings I can rely on for either allowing them to review the SAR's are not allow them access to SAR's?

The FFIEC Manual section on the BSA/AML Compliance Program-Overview includes a section on independent testing which would support the need to provide the third party auditors with documentation of your compliance with suspicious activity reporting. It lists what independent testing should include.

I can understand that the FFIEC manual section might support an internal auditor's ability to have access to specific SARs for review, but I would question if that extends to third-party service providers (either the regular auditors or those specifically employed to review BSA). Everything I read implies that there is very little ability to share any of the SAR details.

The independent testing section indicates independent testing (audit) should be conducted by the internal audit department, outside auditors, consultants or other qualified independent parties. It would be difficult for an auditor to determine if there is a weakness in suspicious activity monitoring and subsequent reporting if they were unable to review the documentation.

I review SARs at bank's all of the time as a third party auditor. It is expected. How else could I comment on adequacy of narrative, proper completion, etc.? The party conducting the independent testing is acting on behalf of the bank and needs access to all bank data. We do not retain copies of SARs, just make notes. No access to SAR data would impair the quality of the audit.

Absolutely they can.

Ditto - I do as MS KayBee does all the time.

This is a little late, but I agree with giving auditors/consultants access to the reports - when I was the BSA officer I always provided SAR copies to our auditors for review. We outsourced our internal audit function to a consulting firm and I gave them access to all information. I don't know how else we could have gotten through a BSA audit...