8.3.7 Continuing Activity Report
A continuing report is filed on suspicious activity that continues after an initial SAR is filed with FinCEN. The FCCM ECM and CRR solutions can be configured to assist with this process.
In the ECM system, when you close and file a SAR on an AML case, a new Continuing Activity (AML_CA) case is created, and an Initial Report is created in the CRR system.
In the CRR system, when an initial SAR is filed with FinCEN, an Acknowledgement is generated by the FinCEN E-File System. For more information on the Acknowledgement, see Acknowledgement section. If using SDTM integration with FinCEN, this Acknowledgement is automatically processed. If not using SDTM, you can complete the suspicious activity report process by performing the Complete SAR Process action. For more information on SDTM, see the Configuring Secure Direct Transfer Mode (SDTM) section in CRR Administration Guide.
Once the Acknowledgment is processed, information about the SAR filing will be available in the Previous Report Summary tab of the CAR case in the ECM system.
The Continuing Activity (CAR) case allows investigators to review activities that occurred after filing the SAR on the previous case. This case must be investigated and concluded within your firm's review period, typically 90-120 days. After this period, if the individual involved in the case continues to be engaged in reportable behavior, a continuing SAR must be filed.
When you file a SAR for the CAR case, the relevant information of the previously filed report will be provided to the Continuing Activity filing and pre-populated in the relevant fields.
The workflow continues in both CRR and ECM systems till the case is closed in the ECM system.
When the Continuing Activity Report SAR is generated, the following field details are auto-populated in the CRR application.