How Should a Financial Institution Document its Decision Not to File a Suspicious Activity Report?
Documentation of a financial institutions decision not to file a SAR can be useful not only in the financial institutions own internal review of its SAR decision-making and reporting procedures, but also to assist internal or external auditors and examiners in their assessment of the effectiveness of the financial institutions suspicious activity monitoring and reporting system. The Federal Financial Institutions Examination Councils BSA/Anti-Money Laundering Examination Manual (FFIEC BSA/AML Examination Manual) states that [t]horough documentation provides a record of the SAR decision-making process, including final decisions not to file a SARExaminers may review individual SAR decisions as a means to test the effectiveness of the SAR monitoring, reporting, and decision-making process.
