Can someone share your policy on when you include information from a previous SAR in a new filing? I know if it's a 90 day update we would include from begining of suspcious activity through current date, but what about when there is a gap? For example, we filed a SAR on "Bob" a year ago for structuring and he's not done it again until now. Is this a "new" SAR or should we include dates/amounts from the last report?

It would not be a "new" SAR. I always carry over dates & amounts.


In the Narrative I usually state something like.

Previous activity reported from XX/XX/XX to XX/XX/XX included: blah blah

Activity from XX/XX/XX to XX/XX/XX was not reported due to: blah blah

Current activity being reported from (you get the idea)

I would consider it a new SAR. Last year's SAR was the initial report. 90 days later there was no followup SAR needed. That SAR process ended.

A year later, you now have a new SAR process started. If you want to be nice, I might stick in a single sentence in the narrative that states that this same activity was reported previously in a SAR on XX/XX/XXXX, but I would not aggregate dollar amounts and dates on page 2 of the SAR.

Heck. Leave some work for law enforcement!!

Oh I don't agree. (just my opinion)

Aren't we all on the same team? If you have additional information - why not share it? Besides, I've noticed the higher the dollar amounts - the quicker the response from law enforcement.

Also, in my neck of the woods we have a lot of "seasonal" activity (if you know what I mean) ... so I get the same people doing the same activity - right around crop season. I like to tie that all together.

We generally conducted a series of 90-day reviews following a SAR-able offense. Once I completed all reviews (generally 3 follow-up reviews) with no repeat activity identified, the case is closed. Once closed, another incident would trigger the opening of a new case. While I might mention the date of a prior SAR for a similar or related incident, I would not treat it as continuation of the pattern for date/dollar aggregation purposes.

Sorry to resurrect this but... we just had an auditor make us aggregate all the way back to the initial SAR on each person until the most recent even though there were gaps of more than 90 days between instances and send in corrections. Where can I find guidance on not aggregating after a cool off of 90 days?

I don't think you will ... from what I understand there is no guidance on this & we're required to carry over the dates/amounts.


But I could be wrong???

OK I will go with the easiest thing and that is do what they say.
Thanks