I balance the daily work and on 08/28 I saw large deposit on a customer done with a check. I remembered I saw same customer with a deposit day before so I start researching the account. There are suspicious check deposits as if moving funds between people dating back to 08/05. I know I have 30 days from 08/28 detection to file SAR but my question is can my date range of suspicious activity for this report begin at 08/05 ?

I've not seen any specific guidance on this though examiners often have personal opinions on the matter, meaning you may get mixed answers. I would contact FinCEN for guidance since the activity is so far back. Then, document who you talked to as an explanation for an examiner as to why you chose the date you did.

Just to be clear, by "08/05", I'm guessing you mean 08/05/2018. If that is the case, you absolutely can and should have the suspicious activity date range start at that point. In fact, examiners expect that you look back within a reasonable timeframe once you first detect new suspicious activity.

Regarding how far back to review once you see some new suspicious activity, it's case-by-case; however, the guideline I'd recommend is a minimum of six months. And if the activity is occurring at the beginning of the six-month period you review, then extend the lookback period for another six months. Repeat that process until you can pinpoint a clear starting point, or, go back for five years - whichever comes first. The vast majority of your cases won't require you to lookback any further than six months, but your procedures should address your approach in such circumstances.

Good point, Pat. I initially read that to be 2005. If it is 8/5/18, I completely agree with your reply.

Thank you for your replies!! I'm sorry for not making it clear but it is 08/05/18.