The Institution’s management will actively search for suspicious activity. When it is discovered, a representative officer will review it and make a recommendation as to whether a Suspicious Activity Report (SAR) should be filed.
A guideline for SAR reporting is that the assigned officer will usually have ten (10) business days to conduct the review and make his or her recommendation. Check the bank’s SAR form for specific instructions. All recommendations will be made in writing and forwarded to the Bank Secrecy Act (BSA) Officer. The BSA Officer is responsible for reviewing the investigating officer’s recommendation, and determining if an SAR should be filed.
The BSA Officer will file the SAR with the appropriate legal and regulatory authorities. All supporting evidence for the SAR will be maintained for a minimum of five (5) years, and will be securely stored. The BSA Officer will report to the board of directors the number of SARs filed each month, along with brief a summary as to dollar amount of the suspicious activities and why they were deemed that way.
Dollar Limits for Filing a SAR
The following guidelines will be used in determining when to file a SAR
- Suspected insider abuse – Report any amount.
- Suspicious transactions where the institution has identified a suspect – Report if amount equals or exceeds $5,000.
- Suspicious transactions where the institution has not identified a suspect – Report if amount equals or exceeds $25,000
- Known violations of the Bank Secrecy Act – Report if amount equals or exceeds $5,000. The BSA Officer will file SARs for amounts less than those specified above, if he or she has reason to believe the transaction is tied to an illegal activity.