I have previously filed a SAR on an unregistered MSB (May 2008). I have continued to monitor and sent another SAR on the same customer but for an ENTIRELY different reason in mid-November. However, upon review of the account in late December, I found one instance of cashing a check for a single person for $1,000 in a single day. The customer has been notified about MSB and what they requirements are if he wants to continue to conduct this type of business. He emphatically told me that he did not want to be an MSB and would discontinue cashing checks for people over $1,000.

Since I found another instance of him conducting a transaction that would put him into the unregistered MSB category, how do I send in the SAR?

First SAR sent May 2008. No other instance found until review in December 2008. Activity actually occurred in late August and I have only found ONE instance.

Is it a correction of the May 2008 SAR eventhough it is well passed the 90 days OR is it a new SAR? I can't find anything thing in the guidance to support either one.

Thanks for your help!

It's a continuation of the orignal SAR. You just cite the dates in which the infraction occurred and reference the previous SAR.