Almost as bad as the Murder on Elm Street - name anything BSA and it's in the consent order
Came up today with Continental National Bank vs. OCC - guess who won The look back is interesting
https://www.occ.gov/static/enforcement-actions/ea2017-051.pdf"(2) The purpose of the Look-Back is to determine whether additional SARs should be
filed for any previously unreported suspicious activity, including cases in which the BSA Officer
or staff identified suspicious activity but failed to adequately support a decision not to file a
SAR, and to review the quality and accuracy of previous SAR filings to determine whether
corrections or amendments are necessary to ensure that the suspicious activity identified was
accurately reported in compliance with 12 C.F.R. § 21.11."