Answer:
FIN-2014-G001 does give instruction for continuing MJ Limited SARS:
"The content of this SAR should be limited to the following information:
(i) identifying information of the subject and related parties;
(ii) addresses of the subject and related parties;
(iii) the fact that the filing institution is filing the SAR solely because the subject is engaged in a marijuana-related business; and
(iv) the fact that no additional suspicious activity has been identified. Financial institutions should use the term “MARIJUANA LIMITED” in the narrative section.
A financial institution should follow FinCEN’s existing guidance on the timing of filing continuing activity reports for the same activity initially reported on a “Marijuana Limited” SAR. The continuing activity report may contain the same limited content as the initial SAR,
plus details about the amount of deposits, withdrawals, and transfers in the account since the last SAR. However, if, in the course of conducting customer due diligence (including ongoing monitoring for red flags), the financial institution detects changes in activity that potentially implicate one of the Cole Memo priorities or violate state law, the financial institution should file
a “Marijuana Priority” SAR."
In my opinion, when it comes to FinCEN guidance, I read "shall" wherever the word "should" appears. That is, I take their suggestions as firm direction. If you do that, you'll have your answer. smile
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