Being fully aware of the confidentiality of SAR disclosures, if your Internal Audit, who performs your BSA Reviews, makes a referral for a SAR Filing, is it permissible to disclose to them that the SAR was filed? Or should we remind them of the confidentiality of SAR filings and they will see that it was filed when they perform their review?

Having Internal Audit perform our reviews is new to me, as my previous institution used an external auditor who only had access during our audits.

It is a felony to disclose a SAR's existence to the subject of the SAR. For this reason banks keep SARs on a "need to know basis." This isn't because it is wrong to let other employees know a SAR has been filed, it's that the more people who have that information, the increased risk of an inappropriate disclosure.

If internal audit is going to see the SAR anyway during the next BSA audit, it becomes a risk-based business decision whether or not you tell them about it now.

Side note: I'll be damned if audit tells me to file a SAR. They might want me to document my decision on particular transactions I may have missed if my system is manual, but audit should not be making SAR decisions IMO.

I would tell them, your recommendation is taken under advisement, I will review the transactions and document my decision. They can review the SAR later if you file one.

Oh we are in total agreement on that, they are not making the SAR decision, but they are asking if the SAR was filed. We have informed them our decision is documented and available during their next review. Thank you

Hey prior poster, you aren't anonymous unless you sign out before posting...