Introductory BSA/AML Examiner School, Providence, RI

Suspicious Activity Monitoring 3. SAR Decision Making Procedure: • Determine whether management’s policies, procedures, and processes include procedures for:  Documenting decisions not to file a SAR.  Escalating issues identified as the result of repeat SAR filings on accounts.  Considering closing accounts as a result of continuous suspicious activity.

Suspicious Activity Monitoring 4. SAR Completion and Filing Procedure: • Determine whether management’s policies, procedures, and processes provide for:  Completing, filing, and retaining SARs and their supporting documents.  Reporting SARs to the board of directors, or a committee thereof, and informing senior management.  Sharing SARs with head offices and controlling companies, as necessary.