SAR Line by Line

FinCEN issued a notice to e-filers that announced an update to the Suspicious Activity Report (SAR) filing format, which went into effect in June 2018. The announcement says that the revisions adhere to the changes listed in FinCEN's February 2, 2017, Federal Register notice. Beginning with the new SAR filings, batch submissions will have to be made in an XML-based file, rather than in the current ASCII fixed-length delimited file format. Other notable changes:

  • A new text field to alert FinCEN that a SAR is being filed in response to a current GTO, advisory or other activity
  • A new "Cyber Event" suspicious activity type category
  • New or modified subtype selections associate with Structuring, Fraud, Gaming activities, Money laundering, Identification/Documentation, Other suspicious activities, Securities/Futures/Options, and Mortgage fraud.
  • New text fields with the IP Address field to record the date and/or timestamp of the first instance of the reported IP address
  • New category of fields to record up to 99 cyber events associated with the suspicious activity
  • New product type selections
  • New subtype selections for securities and futures institutions

Discrete filers started using the new online e-filing form in June 2018. Batch filers may start sending XML-format files with the revised fields beginning in June, but must complete their changeover to the new format within 6 months of the June "go-live" date. ASCII batch files have been accepted through January 1, 2019.

Covered Topics:

  • Who is a subject and who is the victim? And which goes where?
  • Completing the section on the crimes. What can we check? What is each crime and can there be more than one?
  • What are the 24 narrative bullet points and how to make sure they are covered
  • Who can I give supporting documentation to and how?
  • Working with the frontline and the system to generate information that is helpful for fraud
  • Revamping and validating my fraud model. Is my model working?
  • Joint SARs, continuing SARs and confidentiality issues

Who Should Attend?

Tellers, BSA Officers, BSA Support personnel, Deposit Operations, Compliance Officer, Branch Operations will all benefit from attending this webinar.