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#2266278 - 02/14/22 04:16 PM Continuing Activity Report - Different Subjects
ComplyGuy Offline
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Joined: May 2015
Posts: 288
An initial SAR was filed for structuring. Two subjects each completing W/Ds from the same account.

After review of the continuing activity only one of the initial subjects completed continuing transactions.

Would you keep both subjects on the continuing activity report? Would it be a new initial report, and not continuing, since there is only one subject this time? Looking for advice on handling the subjects for this activity.

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#2266289 - 02/14/22 04:57 PM Re: Continuing Activity Report - Different Subjects ComplyGuy
Sunshine Lady Offline
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Sunshine Lady
Joined: Apr 2014
Posts: 681
I would keep the same continuing SAR report and in my narrative say that the other subject does not appear to be continuing the activity and list all of the information for the subject that is still doing the activity.
Last edited by Sunshine Lady; 02/14/22 04:59 PM.
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#2266354 - 02/14/22 11:31 PM Re: Continuing Activity Report - Different Subjects ComplyGuy
Paul Offline
Junior Member
Joined: Jan 2019
Posts: 41
I agree with Sunshine Lady, that is how I have addressed the issue in the past also.

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#2266377 - 02/15/22 04:39 PM Re: Continuing Activity Report - Different Subjects ComplyGuy
ComplyGuy Offline
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Joined: May 2015
Posts: 288
Thanks. That is how I proceeded.

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