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Suspicious Activity Reporting (SAR) Requirements for Financial Institutions

Summary

The following text provides guidance on Suspicious Activity Reporting (SAR) requirements for financial institutions. It discusses various aspects of SAR filing, including Customer Due Diligence (CDD) regulations, FinCEN SAR Electronic Filing Requirements, and SAR character limits.

Key Points

• Financial institutions are not required to perform media searches or screenings under CDD regulations, but may do so based on risk assessment.
• Filers must provide a clear, complete, and concise description of the suspicious activity in the SAR narrative.
• Financial institutions should not file additional SARs to accommodate narratives that exceed the character limit. Instead, they can focus on relevant information, include attachments or supporting documentation.

Analysis

The text emphasizes the importance of providing a clear and complete description of suspicious activity in SAR filings. Financial institutions must balance the need for detailed information with the constraints of character limits. To address this challenge, filers are encouraged to follow these best practices:

• Focus on essential details: Prioritize relevant information that is necessary to clearly describe the suspicious activity.
• Use attachments or supporting documentation: Include additional information as an attachment or note its availability as supporting documentation.
• Retain supporting documentation: Financial institutions must retain all supporting documentation for five years from the date of the report.

By following these guidelines, financial institutions can ensure that their SAR filings are accurate, complete, and concise, while also complying with regulatory requirements.