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Timing of Suspicious Activity Reports

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If a SAR is submitted on the due date using an automated system is it considered to be on time or does it have to be accepted by FinCEN by the due date.

The bank’s automated account monitoring system or initial discovery of information, such as system-generated reports, may flag the transaction; however, this should not be considered initial detection of potential suspicious activity. The 30-day (or 60-day) period does not begin until an appropriate review is conducted and a determination is made that the transaction under review is “suspicious” within the meaning of the SAR regulation.

Reference: FFIEC BSA/AML Examination Manual/Suspicious Activity Reporting/Timing of SAR filing.


First published on 03/11/2018

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