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SAR Information and Verification Requests: What You Need to Know

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In a move to strengthen anti-money laundering (AML) and combating the financing of terrorism (CFT) efforts, financial institutions are required to report certain transactions and maintain detailed records. Here’s what you need to know about SAR information and verification requests:

Report of International Transportation of Currency or Monetary Instruments

Financial institutions must file FinCEN Form 105 to comply with Treasury regulations and U.S. Customs disclosure requirements involving the physical transport, mailing, or shipping of currency or monetary instruments exceeding $10,000 at one time into or out of the United States.

• The report must be completed by or on behalf of the person requesting the transfer and filed within 15 days.
• Financial institutions are exempt from reporting if items are mailed or shipped through the postal service or by common carrier, or if they are shipped to or received from an established customer who maintains a deposit relationship with the bank.
• In cases where transactions are not commensurate with the customary conduct of business, financial institution management must conduct further research and determine whether a SAR should be filed with FinCEN.

Reports of Foreign Bank Accounts

The Treasury requires each person with a financial interest in or signature authority over any foreign financial accounts to report those relationships to the IRS annually if the aggregate value of the accounts exceeds $10,000 at any point during the calendar year.

• The report must be filed by June 30 of the succeeding calendar year using Form TD F 90-22.1.

FinCEN Recordkeeping Requirements

Financial institutions are required to maintain detailed records for certain transactions and activities. These include:

Required Records for Sales of Monetary Instruments for Cash

• Financial institutions must obtain and record identifying information on purchasers, including:
  • Name
  • Date of purchase
  • Type of instrument purchased
  • Serial number of each instrument
  • Amount in dollars

Funds Transfer and Travel Rule Requirements

• Financial institutions must obtain specific information for funds transfers exceeding $3,000.

Records to be Made and Retained by Financial Institutions

• Financial institutions must retain records of certain transactions, including:
  • Extensions of credit in excess of $10,000.

Verification Requests

Financial institutions are required to verify the identifying information of all purchasers. This includes:

• Name
• Address
• Social security number or alien identification number
• Date of birth
• Verification of name and address with an acceptable document

For further guidance on SAR information and verification requests, please refer to the discussion on “Customer Due Diligence” and “Suspicious Activity Reporting” within this chapter.

Contact Information

Examiners are requested to e-mail or fax SAR information and verification requests to their Regional SACM or other designee. For any questions or concerns regarding FinCEN reports or recordkeeping requirements, please contact your local regulatory agency or financial institution representative.