Jump to Content
ABA: The American Bankers Association
Skip Section Navigation

When does the bank file a continuation SAR versus a new SAR for the same customer?

If a bank files a suspicious activity report (SAR) and, during its mandatory 90-day review, finds that the customer has stopped the original suspicious activity but uncovers other, new suspicious activity for the same customer, should the bank file a continuation SAR or does the bank file a new SAR?

The bank should file a new SAR. The SAR instructions state: A continuing report should be filed on suspicious activity that continues after an initial FinCEN SAR is filed.”

The rule appears to contemplate repeated SAR filings for the same activity, but use of continuing reports rather than new reports for activity that is ongoing, meaning the subject of the initial SAR is engaging in the same type of previously reported activity. In your example, however, the initial SAR subject has discontinued the original suspicious activity and is now engaging in different suspicious activity. In this case, the bank should file an initial report within the normal SAR filing deadline of 30 days.

Since the customer is the same, however, it may be important to cross reference prior SARs filed for the same subject in the new SAR narrative to point out the same person was engaging in other types of suspicious activity. Referencing any prior SAR filing(s) assists law enforcement in connecting the dots. (June 2019)

Compliance Hotline

Have a compliance-related question? We're here to help. Members, reach us by phone or email.