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the US, CRI can help with the basic questions of
whether or not to file the SAR, when and how to file “supplemental SARs,” documentation
expectations of the banking and securities regulators,
collection of evidence, and how to report up through
senior management, the Board of Directors, FinCEN,
and both domestic and international law enforcement.
CRI’s SAR specialists are also available to support
your staff and ease SAR bottlenecks.
Example: A top-tier retail bank called CRI experts
to analyze a systematic CTR error, which caused hundreds
of missing or late CTRs. Upon closer investigation,
dozens of unfiled SARs were also discovered. CRI completed
fact-gathering for the bank, prepared draft SARs to
assist with timely filing, performed a quality review
of the new SARs, and advised the bank on how SARs could
be filed without drawing unnecessary criticism from
FinCEN and the federal and state regulators.
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