Sar filing requirements1/25/2024 ![]() Thorough documentation provides a record of the SAR decision-making process and is indicative of a strong BSA program. It is also important to document SAR filing decisions. A comprehensive CIP and due diligence program should ensure that a financial institution can answer the following questions: Are the transactions consistent with the purpose of the account? Is there a reasonable explanation the transactions occurred? What other information is available to aid in the decision (prior investigations, subpoenas, 314(b) information sharing)? The answers to these questions should guide BSA staff in making their decision on whether or not to file a SAR. ![]() However, for those instances that may fall into a grey area, a financial institution should incorporate the information received at account opening and through ongoing monitoring to aid in the SAR filing decision-making process. It should be noted that the reason "no loss to the financial institution or the consumer" is not a valid reason for not filing. If any of the above apply, a SAR should be filed.
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