Financial Crime World

Financial Institution’s Role in Reporting Suspicious Activity: A Guide to Completing Part IV of the FinCEN SAR

As a financial institution, it is crucial to comprehend your role in reporting suspicious activity to the Financial Crimes Enforcement Network (FinCEN). This article provides guidance on how to complete Part IV of the FinCEN SAR, which requires information about the lead financial institution, holding company, agency, or other entity filing the report.

Understanding Your Role

  • As a financial institution, it is essential to understand your role in reporting suspicious activity to FinCEN.
  • You are required to provide accurate and timely information to help law enforcement agencies understand where suspicious activity occurred and take appropriate action to prevent future occurrences.

Scenario 1: Bank Holding Company (BHC) with Enterprise-Wide Compliance Program

  • If your BHC has implemented an enterprise-wide compliance program, you will file all required reports with FinCEN.
  • In this scenario:
    • Part IV would be completed with the information of the BHC.
    • A Part III would be completed for each financial institution where the activity occurred.
    • If the activity occurred at additional branch locations, that information would be entered in Items 64-70 and repeated as necessary.

Scenario 2: Single Depository Institution with Multiple Branches

  • If your institution has multiple branches, you will file your SARs out of the home office.
  • In this scenario:
    • Part IV would be completed with the information of the home office.
    • A Part III would be completed for each branch location where the activity occurred.
    • If the activity occurred at additional branch locations, that information would be entered in Items 64-70 and repeated as necessary.

Scenario 3: Joint SAR Filing

  • In some cases, financial institutions may decide to file a joint SAR with another entity, such as a money services business (MSB).
  • In this scenario:
    • Part IV would be completed with the information of the depository institution filing the SAR.
    • A Part III would be completed for each location where the activity occurred, including the MSB’s location.

Key Takeaways

  • The filing institution listed in Part IV must identify which institutions are joint filers and include their contact information in Part V.
  • If a branch is owned by the financial institution but located separately from its headquarters, it should be reported as a separate location.
  • Agents, such as independent insurance agents or supermarkets that sell money orders, should be reported on a separate Part III.

Contact Information

  • The filing institution should enter the name of the office that should be contacted to obtain additional information about the report. This can include offices such as Compliance, Security, BSA, or Risk Management.

Additional Resources

  • For further guidance on completing Part IV of the FinCEN SAR, contact the FinCEN Regulatory Helpline at 800-949-2732.
  • Financial institutions seeking to report suspicious transactions related to terrorist activity should call the Financial Institutions Toll-Free Hotline at (866) 556-3974.

By following these guidelines and providing accurate information about your financial institution, you can help law enforcement agencies understand where suspicious activity occurred and take appropriate action to prevent future occurrences.