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FinCEN Finalizes New SAR

FinCEN announced updates to the Suspicious Activity Report (SAR) filing format in a notice to e‐filers. The announcement says that the revisions adhere to the changes listed in FinCEN’s February 2, 2017 Federal Register notice and will be live in June 2018. In these new filings, batch submissions will have to be made in an XML‐based file, rather than 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 sub‐type selections associated 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 will start 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 XML within six months of the yet‐to‐beannounced June “go live” date. ASCII batch files will be accepted until January 1, 2019.

TCA will publish additional articles when there is more information available, but remember the CTR form changes are required in May 2018. This new form is already available on the FinCEN e‐filing system.

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  • Provide training to staff on the Bank Secrecy rules
  • Review your program from risk assessment to policies and procedures
  • Test your program for early detection of potential problem

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