Financial Crime World

Filing Suspicious Activity Reports (SARs): Key Takeaways

Introduction

The Financial Crimes Enforcement Network (FinCEN) has provided answers to frequently asked questions regarding the filing of Suspicious Activity Reports (SARs) by financial institutions. These Q&As clarify how financial institutions should handle negative media alerts, data fields, narratives, character limits, and supporting documentation when filing SARs.

Negative Media Alerts

  • No Independent Investigation Required: Financial institutions do not need to independently investigate each of multiple negative news alerts based on the same event.
  • This eliminates unnecessary workload and resources for financial institutions while ensuring that they still comply with regulatory requirements.

Information in Data Fields and Narrative

  • Avoid Duplicate Information: Information provided in other sections of a SAR does not need to be repeated in the narrative unless necessary to provide a clear and complete description of the suspicious activity.
  • This helps maintain clarity and conciseness in the SAR, making it easier for regulators to review and understand.

SAR Character Limits

  • Focus on Key Information: Financial institutions should focus the relevant information in the narrative as much as possible, and may include additional, relevant information as an attachment to the SAR or note that it is available as supporting documentation.
  • This ensures that financial institutions provide accurate and detailed information while adhering to character limits.

Supporting Documentation

  • Retention Requirements: Filers must retain all supporting documentation or a business record equivalent for five years from the date of the report.
  • This maintains transparency and accountability, allowing regulators to verify the accuracy of SARs if needed.

Conclusion

These Q&As emphasize the importance of financial institutions following established policies, procedures, and processes when filing SARs. By focusing on clear and complete descriptions of suspicious activity, avoiding duplicate filings, and maintaining proper supporting documentation, financial institutions can ensure compliance with regulatory requirements while minimizing unnecessary workload and resources.