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Assigning a High Risk Rating to a Repeat SAR Suspect

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Question: 
I have a question regarding repeat SAR filing. Do customers become repeat SAR suspects AFTER a second SAR has been filed on them? At that point would you rate them as high risk and begin performing special due diligence? Or, is it best practice to assign a high risk rating after the filing of the first SAR and begin account monitoring?
Answer: 

While this is largely an opinion-driven issue, mine is that any customer on whom you have filed a SAR is "high risk"; i.e. subject to your highest level of documentation and monitoring. Note that openly using SAR filings in the establishment of risk ratings may communicate the fact that a SAR has been filed to employees who don't need the information.

First published on BankersOnline.com 5/22/06

First published on 05/22/2006

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