Q How often should a credit union file a suspicious activity report (SAR) when there is continuing suspicious activity?
A The Financial Crimes Enforcement Network (FinCEN) recently clarified that financial institutions 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 also may file SARs on continuing activity earlier than the 120-day deadline if the institution believes the activity warrants earlier review by law enforcement. See FinCEN’s SAR Activity Review: Trends, Tips & Issues (Issue 21, May 2012).
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