Reporting Threshold

Posted By: dg

Reporting Threshold - 12/17/15 06:18 PM

We had filed an initial Marijuana Limited SAR on a marijuana related business's activity, that was registered in our state. It is now time to review activity for a possible continuing SAR. The marijuana related activity reviewed in this period is below standard SAR reporting thresholds and does not appear to be suspicious. Is a continuation required? The activity does not implicate any Cole Memo activity involved either. The FinCEN guidance FIN-2014-G001 indicates a FI is required to file a SAR on activity involving a marijuana related business in accordance with the guidance and FinCen's suspicious activity reporting requirements and reporting thresholds.