Answer:
Individuals auditing your BSA program must have access to actual SARs in order to opine on the completeness and accuracy of the SARs filed by the bank. A BSA audit should follow the BSA Exam Manual procedures, and this is a requirement. The auditors are not to retain copies of these documents and should not reference actual names in their audit workpapers or report but must have access to the actual documents and investigation files for SARs filed and investigations that did not result in a SAR.
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