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#1966330 - 10/01/14 09:08 PM 90 Day SAR and Enhanced Due Diligence Review
thisisme08 Offline
Junior Member
Joined: Oct 2012
Posts: 47
Would it be appropriate to discontinue filing a SAR based upon the fact that the Bank has conducted an annual enhanced due diligence review of the customer where Bank personnel met with the Business owner and believe that we’ve identified the reason behind the originally identified suspicious activity? (e.g. it's not suspicious to us anymore; high risk yes, but not suspicious)

The originally identified suspicious activity is still occuring albeit at a lower frequency which also matches the customers statements that they are exiting/reducing their involvement in that particular line of business.

If we do not file, can we be cited for failure to continue to file? or is this a case where an examiner/auditor may not like that we did not continue to file but we've sufficently documented our reason not to file and reached a consensus agreement on our SAR Committee to discontinue filing.

Are we off base with this line of thinking?
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#1966334 - 10/01/14 09:14 PM Re: 90 Day SAR and Enhanced Due Diligence Review thisisme08
rlcarey Online
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rlcarey
Joined: Jul 2001
Posts: 83,352
Galveston, TX
Document and move on.

If an examiner or auditor has a problem with it, then deal with them at that point.
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The opinions expressed here should not be construed to be those of my employer: PPDocs.com

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#1966337 - 10/01/14 09:17 PM Re: 90 Day SAR and Enhanced Due Diligence Review rlcarey
ACBbank Offline
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ACBbank
Joined: Jul 2006
Posts: 4,348
New York City
Originally Posted By: rlcarey
Document and move on.


Agreed.
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"100 victories in 100 battles isnt the most skillful. Subduing the other's military w/o battle is the most skillful." Sun-Tzu

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#1966426 - 10/02/14 02:07 PM Re: 90 Day SAR and Enhanced Due Diligence Review thisisme08
thisisme08 Offline
Junior Member
Joined: Oct 2012
Posts: 47
Thank you gentleman and roaring tiger. smile Have a nice day!
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