Good morning,

We are filing a SAR for a customer who has apparently structured in attempt to avoid CTR. In doing my review this account has been open with our institution for 13 years. In the last 3 years there has only been 2 other transactions, both of which were cash deposits also. One for $3K and one for $5K.

My question is: Do I include all of these last three transactions of cash deposit in the SAR? Or just the one that is apparent structuring? I have struggled to find clear guidance on how far back activity is expected to review and include in SAR's. I am not actually certain and do not believe the past transactions are suspicious in regards to structuring. However it is concerning to me that the acct balance is roughly $23K, and of that the last two years $18K of that is cash only. We clearly have no "source of funds" information on the older transactions.

If you consider them suspicious, include them. If you do not consider them suspicious, do not include them.

The SAR is for you to report all suspicious activity to law enforcement. If the older transactions weren't considered suspicious previously, but in light of new information they are, then include them. If not, then don't. There is no "lookback timeframe." You go back as far as the suspicious activity takes you in the account history.

Thanks very much. This is what I was kind of thinking, and sort of able to find from other sources in researching this topic. Many of them had time frames of 3 months, 6 months, one year, or as long as you need to. I appreciate your response Brian!