Annual SARs will reflect the President's Budget and supporting documentation. 9 As referenced in Question 1, there may be instances where law enforcement requests a financial institution to maintain an account relationship, notwithstanding potential suspicious activity, and the financial institution should continue filing SARs, or continuing activity SARs, as applicable. A SAR has five sections each containing information about the filing institution or the activity in question: Part I - Subject Information Any name, address, social security or tax ID's, birth date, drivers license numbers, passport numbers, occupation and phone numbers of all parties involved with the activity. SARs are required each year for pension plans, including 401 (k) plans, and for welfare plans unless an exemption applies. The SAR may only be shared with: (1) FinCEN; 53. to file a SAR with respect to: A "Suspicious Activity Report" or SAR is a document submitted by Banks or any Money Services Business that help financial authorities supervise unlawful transactions.

A SAR and any information that would reveal the existence of a SAR is confidential, except as is necessary to fulfill BSA obligations and responsibilities. B) The firm may call FinCEN's Hotline at (866) 556-3974. SAR supporting documentation should be described in the SAR narrative and refer to all documents or records that assisted a financial institution in making the determination that certain activity required a SAR filing. Financial institutions are required to file SARs no later than 30 calendar days after the date of the initial detection of facts that constitute basis for filing the SAR. The program must, at a minimum: provide for a system of internal controls to assure ongoing compliance; designate an individual responsible for coordinating and . However, in no case Safeguard requirements such as securing desktop and laptop computers and encrypting email to protect customer information is an obligation of financial institutions under Regulation S-P. A user is now able to place the mouse cursor over any field for the instructions to become visible and obtain detailed information about how to complete any particular field. 12 Regulatory examinations and third-party audit procedures may review individual SAR decisions as a means to test the effectiveness of the SAR monitoring . Banks, bank holding companies, and their subsidiaries are required by federal regulations. Selected Acquisition Report (SAR) Submission. The plan administrator generally must furnish SARs within nine months after the end of the plan year (which is two months after the normal due date for Form 5500s). A financial institution is required to file a suspicious activity report no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a suspicious activity report. The USA Patriot Act further expanded SAR requirements to help combat domestic and global terrorism. The SEC SAR Alert Message Line number [202-551-SARS (7277)] should only be used in cases where a mutual fund has filed a SAR that may require immediate attention by the SEC and wants to alert the SEC about the filing. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction. In situations that require immediate attention, such as terrorist financing or ongoing money laundering schemes, broker-dealers must immediately notify by telephone an appropriate law enforcement authority in addition to filing timely a SAR. FinCEN is a bureau of the US Department of Treasury that is responsible for managing and enforcing Anti-Money Laundering and Bank Secrecy Act rules and regulations. The BSA Exam Manual outlines this timeframe by stating the following: "The SAR rules require that a SAR be electronically filed through the BSA E-Filing System no later than 30 calendar days from the date of the initial detection of facts that may constitute a basis for filing a SAR. FinCEN requests that financial institutions use only the updated mandatory SAR form (as of February 1, 2019) and reference this advisory using the following key term in SAR field 2 (Filing Institution Note to FinCEN): "FENTANYL FIN-2019-A006" to indicate a possible connection between the suspicious activities being reported and activities . As required by Section 1503 of the Secure and Fair Enforcement for Mortgage Licensing Act of 2008 (SAFE Act), a NMLS unique identifier is permanently assigned to each state-licensed or federally registered mortgage loan originator (MLO), as well as each company, branch, and control person that maintains a single account in NMLS. Money Laundering Red Flags Covered financial institutions are required to establish and maintain written procedures that are reasonably designed to identify and verify beneficial owners of legal entity customers and to include such procedures in their anti-money laundering compliance program required under 31 U.S.C. According to the U.S. Financial Crimes Enforcement Network (FinCEN), SARs are part of anti-money laundering regulations and cover unusual or suspicious activity that might . The Bank Secrecy Act (also known as 'The Currency and Foreign Transactions Reporting Act of 1970') requires financial institutions to disclose any suspicious economic activity. the FinCEN SAR Filing Instructions FinCEN has clarified and expanded the SAR filing instructions to be interactive and field specific. The decision to file a SAR is an inherently subjective. The SAR for the quarter ending December 31 is the annual SAR. While FinCEN's new uniform filing system, discussed in II.D. Mutual funds may also, but are not required to, contact the SEC to report situations that may require immediate attention by the SEC. As auditors, we focus on whether a financial institution has an effective SAR decision-making process, not individual SAR decisions. Calling the SEC SAR Alert Message Line does . The anti-money laundering compliance officer should do all of the following except A) notify customers immediately when a SAR is being filed. Anan institution may delay filing SAR for an additional 30 an calendar days to identify a suspect. A suspicious activity report (SAR) is a tool provided under the Bank Secrecy Act (BSA) of 1970 for monitoring suspicious activities that would not ordinarily be flagged under other reports (such as. examination process, examiners should review individual SAR filing decisions to determine the effectiveness of the bank's suspicious activity identification, evaluation, and reporting process. If no suspect can be identified, the time period for filing a SAR is extended to 60 days. above, will require the use of one form by all businesses subject to FinCEN SAR regulations, the uniform form has been designed to be used by a range of filer types, with required data fields for each type of filer reflecting the kinds of activities reported by those specific filer . The Program Manager (PM) will submit the annual SAR within 60 days after the President transmits the following fiscal year's budget to Congress. Timing of a SAR Filing . If no suspect was identified on the date of detection of the incident requiring the filing, a national bank may delay filing a SAR for an additional 30 calendar days to identify a suspect. In the event of a suspicious transaction or activity, financial institutions are required to conduct suspicious activity reporting by filing a SAR. (c) Exception. Understanding Its Suspicious Activity Reporting (SAR) Requirement from complianceonline123 Section 314 (a) authorizes a federal, state, local, or foreign law enforcement agency investigating terrorism or money laundering to request that FinCEN solicit, on its behalf, certain information from banks and other financial institutions about an individual, entity or organization about which the law enforcement entity is seeking information. Insurance companies wishing voluntarily to report suspicious transactions that may relate to terrorist activity may call the Financial Crimes Enforcement Network's Financial Institutions Hotline at 1-866-556-3974 in addition to filing timely a SAR if required by this section. If no suspect can be identified, the time period for filing . This regulation requires every national bank and savings association to have a written, board approved program that is reasonably designed to assure and monitor compliance with the BSA. SAR became the standard form of reporting suspicious activity in 1996. The SAR rules require that a SAR be electronically filed through the BSA E-Filing System no later than 30 calendar days from the date of the initial detection of facts that may constitute a basis for filing a SAR. If no suspect was identified on the date of detection of the incident requiring the filing, a financial institution may delay . A Suspicious Activity Report (SAR) is a standardized document that U.S. financial institutions must file with the Financial Crimes Enforcement Network (FinCEN) if they suspect possible money laundering, terrorism funding or fraud. Documentation may include transaction records, new account information, tape recordings, e-mail messages, and correspondence . 5318 (h) and its implementing regulations.