Compliance Alliance Q&A 5/21/2019

Question:

By what day do we have to file the continuing activity SAR? Is it Day 90 or Day 120?

 

Answer:

The guidance provides that "Financial institutions with SAR requirements may file SARs for continuing activity after a 90 day review with the filing deadline being 120 days after the date of the previously related SAR filing. Financial institutions may also file SARs on continuing activity earlier than the 120 day deadline if the institution believes the activity warrants earlier review by law enforcement." https://www.fincen.gov/sites/default/files/shared/sar_tti_21.pdf (p. 53).

 So the review period itself is 90 days, but the filing deadline is 120 days from the last one filed, to include the additional 30 days allowed for filing. It does also say that the bank has the option of filing earlier than the 120 days if it believes that law enforcement should review earlier.

Financial institutions with SAR requirements may file SARs for continuing activity after a 90-day review with the filing deadline being 120 days after the date of the previously related SAR filing. So, for filings where a subject has been identified, the timeline is as follows:

Identification of suspicious activity and subject: Day 0.

Deadline for initial SAR filing: Day 30.

End of 90 day review: Day 120.

Deadline for continuing activity SAR with subject information: Day 150 (120 days from the date of the initial filing on Day 30).

If the activity continues, this timeframe will result in three SARs filed over a 12-month period.


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