![]() Of course, an expeditious review, wherever possible, is recommended and can be of significant assistance to law enforcement. The time to file a SAR starts when the organization, in the course of its review or on account of other factors, reaches the position in which it knows, or has reason to suspect, that the activity or transactions under review meets one or more of the definitions of suspicious activity. ![]() The fact that a review of customer activity or transactions is determined to be necessary is not necessarily indicative of the need to file a SAR, even if a reasonable review of the activity or transactions might take an extended period of time. It may be appropriate for organizations to conduct a review of the activity to determine whether a need exists to file a SAR. (6/2001)Īnswer 7: The SAR rules require that a SAR be filed no later than 30 calendar days from the date of the initial detection of the suspicious activity, unless no suspect can be identified, in which case, the time period for filing a SAR is extended to 60 days. Moreover, the information contained in a SAR that one law enforcement agency has declined to investigate may be of interest to other law enforcement agencies, as well as supervisory agencies. The filing of SARs on continuing suspicious activity provides useful information to law enforcement and supervisory authorities. If conduct continues for which a SAR has been filed, the guidance set forth in the October 2000 SAR Activity Review (Section 5 – Repeated SAR Filings on the Same Activity) should be followed (i.e., organizations should report continuing suspicious activity with a SAR being filed at least every 90 days) even if a law enforcement agency has declined to investigate or there is knowledge that an investigation has begun. In other instances, a law enforcement agency has contacted a financial institution to report that it does not intend to investigate the matter reported on the SAR. Answer 4: In some instances, after the filing of one or more SARs, law enforcement has contacted a financial institution requesting more specific information with regard to the suspect activity or requesting identified supporting documentation.
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