By: David Lutz, Supervisor at P&G Associates
Supervisor, Internal AuditAccording to a notice issued by the Financial Crimes Enforcement Network dated February 24, 2012, financial institutions subject to Bank Secrecy Act reporting will be required to use electronic filing (E-Filing) for certain FinCEN reports beginning no later than July 1, 2012. Financial institutions must electronically file all reports (e.g., CTR, SAR) except the Report of International Transportation of Currency or Monetary Instruments (CMIR) and the Report of Cash Payments Over $10,000 Received in a Trade or Business (Form 8300). The new mandatory reporting requirement has been issued in an effort to improve efficiency, reduce government and industry costs, and enhance the ability of investigators, analysts, and examiners to gain timely access to information.
Electronic filing will look to improve the accuracy of financial institution reporting and offer a faster method of routing information to law enforcement. FinCEN has updated E-filing to include validation checks on CTR and SAR file submissions. CTR Validations include technical feedback and warnings to filers when submitted files contain significant formatting errors. SAR Validations will look to automatically prevent errors from being submitted or will be returned to the filer with an acknowledgement file and an explanation.
Reporting will be provided to financial institutions free of charge through the BSA E-filing system. In addition to a greater accuracy of reporting, this method will enhance security and privacy of customer information through the secure E-filing system.
FinCEN will grant a limited number of temporary exemptions to institutions that demonstrate substantial difficulties in meeting the July 1, 2012, deadline. Exemption categories include Money Services Business and small credit unions lacking internet connectivity, major system conversion to enable batch and computer-to-computer CTR filing, and other extraordinary circumstances.
Institutions that have not already done so should access the BSA E-filing home page to enroll before July 1, 2012.
Senior Manager - BSA/AML
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