We place all accounts on which we've filed SARs on high risk monitoring. However, how long after the suspicious activity has ended should we continue monitoring? There are some accounts being monitored that had one SAR filed, two years ago.

We look at the whole picture:
--CTR & SAR reporting history
--Business Industry
--NRA or Foreign
--Cash activity ($amounts and # of transactions)
--Wire transfer activity ((specially international)
--ACH activity
--other relationships with the bank ((loans, Letters of credits)

As you can see, you need more than one factor to determine your customer's risk rating....

A simpler answer: If there is no other RISK FACTORS involve with the customer, then, perhaps the SAR transaction was a one time issue...therefore, I think that 24 months is a reasonable timeframe to monitor such customer....

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It's hard to generalize, a critical factor is why the first SAR was filed. In general, I would suggest that if in six months you have seen nothing related to your first instance your monitoring efforts serve no purpose.

You shoudl decide how much monitoring to give them, then document it. Documentation is key.

In my office, I have a monitoring risk form which defines risk based on points. A SAR filed on a customer adds points, but depending on the rest of the points earned on the form, the customer may not be high risk despite the SAR.

We ran into the same issue during our recent examination. The FRB suggested that we put the customer back into their appropriate risk category if no suspicous activity is detected after a supplemental review. We also use a point system to establish the appropriate risk catetgory. A SAR adds extra points. However, the other factors may allow the customer to be slotted into a low or moderate risk category.

Thank you for all your help! It's much appreciated.