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Documenting Business Activity without Filing SARs

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We have a business customer that was flagged in our anti-money laundering software for structuring cash deposits between $6000 and $9000. At the time it appeared that he was structuring, and two SARs were filed. After watching the account and investigating the activity more, the deposits appear to be regular activity. We know that once we begin filing a SAR and then stop, we need to document reasons why and future activity in another fashion. How do we continue documenting activity without filing SARs?

Once you have determined that you are looking at expected, normal activity for the business you should indicate that observation in a memo to the file that you're maintaining for your SAR file/don't file determination, and include a statement that you won't be filing a SAR. Then, keep an eye on the customer's activity as you have been for at least one more quarter, again confirm there's no SAR filing needed and review your risk assessment of the customer to determine whether you need to continue monitoring at the level you have, or if you can reduce that monitoring to that appropriate for a lower-risk customer. At that point, everything shifts to your normal monitoring routine unless and until you see something that warrants another SAR decision.

First published on 6/16/08

First published on 06/16/2008

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