Suspicious Activity Report Review Period: Understanding the Financial Crimes Enforcement Network Guidelines

Financial Institution Account Review Period

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Question

According to the Financial Crimes Enforcement Network, after an initial suspicious activity report has been filed for a customer, a financial institution must perform a continuing review of the account for a period of how many days?

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The Financial Crimes Enforcement Network (FinCEN) is a bureau of the United States Department of the Treasury that is responsible for the collection, analysis, and dissemination of financial intelligence related to money laundering and other financial crimes. In order to combat money laundering and other financial crimes, FinCEN requires financial institutions to file Suspicious Activity Reports (SARs) when they suspect that a customer is engaged in suspicious activities.

According to FinCEN guidance, after filing an initial SAR, a financial institution must perform a continuing review of the account for a period of 90 days. This continuing review is intended to allow the financial institution to detect and report any additional suspicious activities that may occur after the initial SAR was filed.

During the 90-day continuing review period, the financial institution should monitor the account for any additional activity that may be related to the initial suspicious activity or may be indicative of other suspicious activity. The financial institution should also consider whether it is necessary to file additional SARs based on any new information that becomes available during the continuing review period.

It is important to note that the 90-day continuing review period is a minimum requirement, and financial institutions may need to extend the review period if they believe that additional suspicious activity may be occurring. Additionally, financial institutions may be required to file additional SARs even after the continuing review period has ended if they become aware of new information that indicates ongoing suspicious activity.