In case you missed it, FinCEN recently announced revisions to the Suspicious Activity Report (SAR). These revisions do not create any new regulatory requirements or change the current SAR reporting requirements. They do; however, create some new, modified and expanded options for reporting suspicious activity.
Some of the changes include:
- A new text field to alert FinCEN that a SAR is being filed in response to a current GTO (Geographic Targeting Order), advisory or other activity;
- A new suspicious activity type for “Cyber Event”;
- New or modified options for Structuring, Fraud, Gaming activities, Money laundering, Identification/Documentation, Other suspicious activities, Securities/Futures/Options, and Mortgage fraud;
- New text fields with an 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; and,
- New subtype selections for securities and futures institutions.
Additionally, these revisions require batch filers to submit the updated SAR data in an XML based file format, rather than the current ASCII based fixed-length delimited file. The new SAR will be available on the BSA E-Filing System to discrete (single) filers sometime in June 2018. Batch filers with have six months after the yet-to-be-announced June “go-live” date to change over to the XML format. ASCII batch files will be accepted until January 1, 2019.
We will include an update on the changes in our August 9, 2018, Suspicious Activity Reporting Video Webinar!