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Despite 90-day SAR Window, Banks Face Uncertainty in Following Up Suspicious Activity
By Brian Monroe
printWhen it comes to reporting ongoing suspicious activity, even following federal regulations to the letter may not be enough to stave off enforcement actions, say compliance professionals. Under U.S. Treasury Department guidance, anti-money laundering (AML) compliance officers have 90 days to follow up on previously filed suspicious activity reports (SARs) with additional accounts of any possible crimes. The bureau's Financial Crimes Enforcement Network (FinCEN) issued recommendations on the three month period in October 2000 and April 2005. The follow-up period "serves the purposes of notifying law enforcement of the continuing nature of the activity, as well as provide a reminder...
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