What should the procedures for escalating issues identified from repeat SAR filings include?

The procedures for escalating issues identified from repeat Suspicious Activity Report (SAR) filings should include a review by senior management and legal staff. Senior management plays a crucial role in the oversight of the institution’s compliance program and their involvement is necessary to ensure that appropriate actions are taken based on the severity of the identified issues. Engaging legal staff in the review process helps ensure that any actions taken align with legal standards and minimize the institution's liability, particularly regarding potential criminal activity flagged by these SARs.

Moreover, involving senior management facilitates a higher level of scrutiny and helps ensure that there are adequate resources allocated to address and mitigate the risk indicated by repeat SAR filings. This collaborative approach enhances the effectiveness of the response plan and establishes a culture of compliance within the organization. Ultimately, this layered review process is essential in ensuring that the institution maintains adherence to the Bank Secrecy Act (BSA) obligations while safeguarding its operations and reputation.

In contrast, monitoring member financial activity, while valuable, is more of a preventative measure rather than a direct response to repeating issues that have already been flagged. Consultation with law enforcement is typically a follow-up action that may occur after internal reviews, rather than a part of the escalation procedures for internal assessments. Informing the general