90 Day SAR Narrations
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Just when you think you know everything you get stopped in your tracks! I found that out recently when researching SARs. As we all know, organizations should report continuing suspicious activity with a SAR being filed at least every 90 days. Well, I recently discovered when filing a 90-day SAR that the date range and dollar amounts should be cumulative, encompassing the entire period of suspicious activity (not jus t the last 90 days). This guidance can be found on page 32 of the April 2005 SAR Activity Review. In the narration; however, you should indicate this is the 2nd (3rd, 4th, etc.) SAR filed on this person and the total of the activity in just the last 90 days. This information can be very helpful to law enforcement agencies. Just goes to show you never know it all.
Isn't compliance wonderful?