An account has been brought to my attention. I have reviewed the account and at this point I don't think there is enough to file a SAR. I want to monitor the account a little longer. When does my timing start on when I need to file a SAR? Does it start when I was alerted or when I determine there is enough information to actual make the decision to file or not file?

When you make the decision whether or not you have enough information to file or not file the SAR,

agree. When you make the decision.

Thanks, that is what I thought. Just wanted to be sure.

The 30-day SAR clock starts from the "initial detection" of suspicious activity, not the date of the decision made by the BSA officer.

Time for reporting. A national bank is required to file a SAR no later than 30 calendar days after the date of the initial detection of facts that may constitute a basis for filing a SAR. If no suspect was identified on the date of detection of the incident requiring the filing, a national bank may delay filing a SAR for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction. In situations involving violations requiring immediate attention, such as when a reportable violation is ongoing, the financial institution shall immediately notify, by telephone, an appropriate law enforcement authority and the OCC in addition to filing a timely SAR.


https://www.bankersonline.com/forum/ubbthreads.php/topics/2057604/SAR_timing#Post2057604

Found this in the BSA manual.

The phrase "initial detection" should not be interpreted as meaning the moment a transaction is highlighted for review. There are a variety of legitimate transactions that could raise a red flag simply because they are inconsistent with an accountholder’s normal account activity. For example, a real estate investment (purchase or sale), the receipt of an inheritance, or a gift, may cause an account to have a significant credit or debit that would be inconsistent with typical account activity. The bank’s automated account monitoring system or initial discovery of information, such as system-generated reports, may flag the transaction; however, this should not be considered initial detection of potential suspicious activity. The 30-day (or 60-day) period does not begin until an appropriate review is conducted and a determination is made that the transaction under review is "suspicious" within the meaning of the SAR regulation.7

Yes, and to answer your question, you'd need to conduct another account review to make a SAR determination.