Money Service Business
Should financial institutions file additional SARs on the same suspicious activity to accommodate narratives that are longer than the SAR narrative character limits? No. Filers must provide a clear, complete, and concise description of the suspicious activity that led to the decision to file the SAR.13 A financial institution that […]
Does a financial institution need to repeat information in the SAR narrative that has already been included in other SAR data fields? No. As stated in the SAR instructions, information provided in other sections of a SAR does not need to be repeated in the narrative unless necessary to […]
What if there are multiple negative news alerts based on the same event, is a financial institution expected to independently investigate each of those alerts? No. In circumstances where there are multiple negative news alerts (as identified through monitoring for unusual or suspicious activity) based on the same underlying events, […]
Is a financial institution required to file a SAR based solely on negative news? No. The existence of negative news related to a customer or other activity at a financial institution does not by itself indicate that the criteria requiring the filing of a SAR have been met, and does […]
Is a financial institution required to terminate a customer relationship following the filing of a SAR or multiple SARs? No. There is no BSA regulatory requirement to terminate a customer relationship after the filing of a SAR or any number of SARs. The decision to maintain or close a customer […]
Should a financial institution file a SAR solely on the basis of receiving a grand jury subpoena or other law enforcement inquiries? No. The receipt of a law enforcement inquiry, such as a grand jury subpoena, does not by itself indicate that the criteria requiring the filing of a SAR […]
Yes. Law enforcement may have an interest in ensuring that certain accounts and customer relationships remain open notwithstanding suspicious or potential criminal activity in connection with the account. A financial institution may decide to maintain an account based on a written “keep open” request from a law enforcement agency, however, […]