Timing of Suspicious Activity Reports

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.