Time Frame for Filing a New SAR after the Original

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Question:

In suspicious activity reporting, how long after the original SAR is filed should the bank track and try to connect to that ring before filing a new SAR. Updates or amendments to SAR's filed in the past seem to diminish the value of the information if we are updating reports from sometimes years in the past.

Answer:

I'm not sure I'm following the question except that it appears to ask about a continuation of a SAR.

From page 27 of the October 2000 SAR Activity Review:

"One of the purposes of filing SARs is to identify violations or potential violations of law to the appropriate law enforcement authorities for criminal investigation. This is accomplished by the filing of a SAR that identifies the activity of concern. Should this activity continue over a period of time, it is useful for such information to be made known to law enforcement (and the bank supervisors). As a general rule of thumb, organizations should report continuing suspicious activity with a report being filed at least every 90 days. This will serve the purposes of notifying law enforcement of the continuing nature of the activity, as well as provide a reminder to the organization that it must continue to review the suspicious activity to determine if other actions may be appropriate, such as terminating its relationship with the customer or employee that is the subject of the filing."

If you had activity which in itself would trigger another SAR before this 90 days, it should be filed. If there is continued suspicious activity, start your process at about 60 or 70 days so you file within the 90 days recommended. We have heard of banks criticized for going even a week beyond this period.

If this doesn't answer your question you might go back and review the SAR Filing Guidance.

First published on BankersOnline.com 3/19/12