Marijuana Limited SAR

Based on what I read on FinCEN Guidance 2014-G001 on MRBs and Marijuana LIMITED SAR filing, I’m understanding this as FIs should file basically letting FinCEN know that we have an MRB yet they are not violating any law or no suspicious activity has been identified.

So couple questions comes to mind:

1. If no suspicious activity is detected, then no dollar amount will be reported? And no date range?

2. In the narrative, do we just identify the business, related parties, address?

3. What boxes do we need to check on the SAR form? “Other” and type “Marijuana Limited SAR”?

4. If we start filing a Limited SAR and continue the relationship, then do we forever continue to filing Limited SAR (if nothing changes)?

From the Guidance: The content of this SAR should be limited to the following information: (i) identifying information of the subject and related parties; (ii) addresses of the subject and related parties; (iii) the fact that the filing institution is filing the SAR solely because the subject is engaged in a marijuana-related business; and (iv) the fact that no additional suspicious activity has been identified. Financial institutions should use the term “MARIJUANA LIMITED” in the narrative section.

This answers questions 1, 2, and 3.

The answer to 4 is yes.