4.7. Escalation for Expedited Review

Effective from 3/8/2022

In certain cases, an alert or case may need to be dispositioned and an STR or SAR filed more rapidly than usual processes allow. In such cases, the alert will be dispositioned and the STR or SAR filed according to the expedited review timeline as laid out below.

Circumstances where expedited review is expected include:

	•	The activity requires immediate attention (as defined above); and
	•	The facts available at the alert review stage are or may be sufficient to warrant an STR or SAR filing without further investigation.

The following table summarizes the recommended suspicious activity review, investigation, and reporting timelines in the event of escalation for expedited review.

Action	Maximum Timeline in Calendar Days
Decision on whether to file an STR or SAR and filing of first STR or SAR	24 hours from decision to file
Filing of STR or SAR on continuing activity	Upon filing an STR/SAR pertaining to an account holder, LFIs are expected to implement enhanced monitoring on such account holders. In the case of continued suspicious activity detected against said account holder, LFIs are expected to expeditiously file an STR/SAR with the FIU.