By Reena Miller | Senior BSA Auditor
FinCEN’s new Suspicious Activity Report (“SAR”) form, which was made mandatory as of April 1, 2013, now contains check box items for various key terms in order to help the Federal government identify individuals, groups and organizations involved in fraud, terrorist financing, money laundering, and other crimes. Such categories are structuring, terrorist financing, fraud, casinos, money laundering, identification/documentation, etc., and within each section, there are subcategories that will further explain each suspicious activity (i.e., Trade Based Money Laundering/Black Market Peso Exchange, transaction out of pattern for customer [s], Account takeover, Elder financial exploitation, etc.
According to the SAR trends, tips and issues (issue 23), which was published in May 2013, when completing the new SAR form Financial Institution are now able to just check off the corresponding item box that will identify the suspicious activities. They are no longer required to include such key terms in the narrative sections if a check box item exists for each term item. However, Financial Institutions may include those key terms as an option within the narrative as best practice.
Prior to this new SAR form, financial institutions used to have to include the best description of each term within the narrative section of the old form. By introducing this new form, it’s one less thing to worry about for financial institutions. FinCEN has made it a bit easier for financial institutions to identify the suspicious activity in a quicker and more efficient way. You can access a sample of this from via FinCEN website.
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