New SAR or Continuing SAR?

Posted By: unknown

New SAR or Continuing SAR? - 01/08/21 04:24 PM

We filed a SAR on an individual for cashing checks from business account in a structuring manner. Continuing SAR will be filed in 90 days since the activity continues.

We recently discovered that this same individual has sent runners to cash checks from a different business account which appears to be structured.

Do we file a new SAR solely on recently discovered activity? Or can we add it to the continuing SAR when it comes due in 90 days?
Posted By: rlcarey

Re: New SAR or Continuing SAR? - 01/08/21 04:37 PM

Structuring is structuring. If additional structuring has been uncovered, then I would include it in my final SAR immediately after terminating any relationship with this customer.
Posted By: chuckchuck

Re: New SAR or Continuing SAR? - 01/13/21 03:36 PM

File a correction for your latest SAR including the new activity and the new suspects