Continuing SAR filing prior to 90 day review.

Answered by:

Question:

Can we file a continuing SAR before the 90-day review period?

Answer:

Yes. If new activity has occurred that precipitates expedited notification to FinCEN, a continuing SAR can be filed prior to the 90 day review period. If the activity is the same as the prior filing and not of concern to national security or harm to others, the institution should wait to conduct a full 90 day review.
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