Time Frame to File an SAR

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Question:

As per section 103.18 of the Bank Secrecy Act, "A bank is required to file a SAR no later than 30 calendar days after the date of initial detection by the bank of facts that may constitute a basis for filing a SAR." The question is, when is the initial detection required to occur? For example, if it takes say 14 days for the detection of the suspicious activity, does the bank have 30 days from that date to file the SAR?

Answer:

The 30 days starts from the date the bank becomes aware of the activity the makes the bank suspicious. If it takes 14 days after an event for the bank to become aware of the activity, the 30 days begins at the time the bank becomes aware.

For example, assume you have a customer who has been kiting checks between your bank and another for two months. You become aware of the pattern on March 10, 2005. Your filing must take place by April 9, 2005. By then you will have had time to figure out that the activity has been going on since January, and you'll say so in your SAR.

First published on BankersOnline.com 5/2/05