Скачать или смотреть AML/CFT: Continuing SARs FAQ

Partner with Banker's Compliance Consulting AML/CFT Group: https://bit.ly/BSA-AML-CFT

The guidance on continuing suspicious activity is overly complicated, and examiners have been misinterpreting the rules, citing banks for not strictly following the 30-day and 90-day timeline for reviewing activity after filing a Suspicious Activity Report (SAR). However, the guidance allows for a risk-based approach - banks are not required to conduct a 90-day lookback after every SAR filing, and can file a new SAR outside of the 30-day and 90-day windows if warranted. Examiners should not be citing banks for not strictly following the timeline guidance, as it was not intended to be that prescriptive. Banks have flexibility in how they conduct their post-SAR reviews.

Clip taken from BCC Oct AML/CFT. Find training here - https://bit.ly/BCC-AML-CFT