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Excerpt from the SAR Activity Review
SAR Form Preparation & Filing

The information obtained from the filing of SARs plays an important role in identifying potential and actual illegal activities, such as money laundering, fraud and abuse, and it assists in the detection and prevention of the flow of illicit funds through our financial system. For these reasons, it is critical that the information being conveyed in SAR filings be as accurate and complete as is possible. The following tips will assist in ensuring the accuracy and completeness of SAR filings:

  • The narrative section of the SAR should provide a detailed description of the known or suspected violation of law or suspicious activity. While detailed suspect information may not always be available (e.g., in situations involving non-account holders), such information should be included to the maximum extent possible.
  • Supporting documents should never be attached to a SAR form. If a filer has documentation relating to the suspicious activity being reported, reference should be made to the existence of the documentation in the narrative section of the SAR form. However, the actual documentation should be maintained on file at the organization for a minimum period of five years.
  • Filers are encouraged to adopt and utilize a standardized format for identifying the reporting organization on the SAR form (e.g., Community Bank of the U.S.A., or Community Bank of the United States of America). Along with the organization name and EIN, a complete address, including city, state, and zip code, should always be included on the SAR form.
  • A SAR should always identify the organization’s primary Federal regulator.
  • When reporting the “total dollar amount involved in known or suspicious activity,” only whole dollar amounts should be listed, no cents (e.g., indicate $10,000, not $10,000.74). If there is no actual dollar amount connected to the suspicious activity, “0” should be entered on the form. Monetary values reflected on the SAR form should always be entered as U.S. dollars. If a suspicious transaction involves a foreign currency, indicate this fact in the narrative section of the SAR form--also provide the type/name of the foreign currency, the amount of the transaction, and the conversion rate used to reach the U.S. dollar figure.
  • SARs are properly filed with the IRS’ Detroit Computing Center (DCC). Magnetically filed (disk) and paper SARs should be addressed to “FinCEN, Detroit Computing Center, P.O. Box 33980, Detroit, MI 48232-0908.”
SAR Form Completion—National Overview
The following chart provides a statistical breakout of the percentage completion rate for each field on the SAR form for all SARs in the national database (approximately 400,000 records at time of this report). Each row of the chart is keyed to successive fields on the SAR form. Additional columns represent all financial institutions, grouped under the appropriate regulator as reported by the institution. Intersection of a row and column shows the percentage completion rate for the specific field for all financial institutions for each regulator, and indicates if the percentage completion rate varies statistically above (A) or below (B) the national average for that field. (The “Other” column represents SARs filed either by non-bank financial institutions or by banks that did not identify their regulator.)

The following chart provides a statistical breakout of the percentage completion rate for each field on the SAR form for all SARs in the national database (approximately 400,000 records at time of this report). Each row of the chart is keyed to successive fields on the SAR form. Additional columns represent all financial institutions, grouped under the appropriate regulator as reported by the institution. Intersection of a row and column shows the percentage completion rate for the specific field for all financial institutions for each regulator, and indicates if the percentage completion rate varies statistically above (A) or below (B) the national average for that field. (The “Other” column represents SARs filed either by non-bank financial institutions or by banks that did not identify their regulator.)

Excerpted from SAR Activity Review Issue 1 , page 24







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