The 7th issue of the SAR Activity Review used to list the various SAR violations with descriptions and possible criminal statutes. Has this list been updated since the new form went into effect?

No, it hasn't and I can't imagine anyone having the courage to try.

The "legacy" form loosely followed a simple formula: any checkbox reflected a crime (oftentimes rooted in bank fraud) to which a citation to statute could be provided. The FinCEN SAR reflects no such logic; many of its check boxes describe activity that might indicate why the bank is suspicious, but the activity itself is not illegal.

For example, exchanging small bills for large bills or an inability to explain a customer's source of funds might reasonably cause a bank to suspect money laundering. They are a possible symptom of illegal activity, but they are not illegal.

In its Pulbic Comments Disposition Statement, FinCEN said:

The categorizations are not intended to determine criminal activities but to serve as a way to group items in a manner that would allow financial intuitions to quickly identify specific suspicious activities. The Unified SAR was designed to allow multiple industries a method of reporting suspicious activities that could be analyzed in many ways.

Initially, I did not think the change made a lot of sense. Now, I've had more than a year to think about it and am quite certain that "all the little boxes" make no sense at all and dilute rather than improve SAR quality.

Only a government committee could have concluded that this was a good idea.