Can financial institutions file SARs on continuing activities earlier than the 120-day deadline?

Financial institutions can indeed file Suspicious Activity Reports (SARs) on continuing activities earlier than the 120-day deadline. The Bank Secrecy Act (BSA) and its associated regulations allow for the filing of SARs whenever a financial institution detects suspicious activity. While the institution typically has up to 120 days to file after determining that a suspicious activity report is necessary, it is not restricted from filing at any point before that deadline. This flexibility enables institutions to promptly report serious suspicious activities, especially if they believe that early reporting could aid in an ongoing investigation or in preventing further illicit actions. Such proactive measures underscore the institution's commitment to compliance and assist law enforcement efforts in addressing potential criminal behavior.