If after receiving a subpoena, we do our look back and determine now we would consider certain activity suspicious, how do we indicate we are just now reporting because of the subpoena without saying we got the subpoena? More simply said, how can we report this activity without it being considered late? Of course the date of determination would be the date we learned of the subpoena. But in the SAR we shouldn't say DOD is today because we got a subpoena. Any thoughts of how you've said this without saying this would be appreciated. Thanks

Unless it is a grand jury subpoena, why can't you mention it? If it is a grand jury subpoena, then your internal documentation file would explain the issue.

I stated when we were contacted by law enforcement and "Upon reviewing the account for subpoena" what was found with dates of when I suspected it started. It isn't late because you discovered the issue when it was brought to your attention, no different than if you or another employee caught it.

If you found this only because of a subpoena you need to review your system parameters and thresholds. The SAR writeup is pnly a small portion of the issue,

Thanks for your input. Yes, this was a grand jury subpoena. Information was already identified, but subpoena certainly placed a different perspective on the transaction.