The Fine Points Of SAR Completion

by Sam Ott, BOL Guru

Are you struggling with the task of completing Suspicious Activity Reports (SARs)? There are many fine points that are not specifically addressed in the SAR instructions. Fortunately, however, through three years of the publication SAR Activity Review, FinCEN has provided ample additional guidance to help fill in the blanks.

This article provides supplemental tips for completing each section of a SAR as well as guidance for dealing with particular circumstances, such as continuing suspicious activity and errors in filings.

PART I Reporting Financial Institution Information

Adopt a standardized format for identifying your institution and make sure all employees who complete SARs follow it . Avoid abbreviations and name variations.;
Always provide the standardized name, EIN and complete address, including city, state and zip code ;
Check the appropriate box for your primary Federal regulator;
Indicate the address of the office where the activity occurred. If multiple branches were involved, check the box and list the location in PART V, the narrative section;
List the account numbers affected and whether the account has been closed. If more than four accounts are involved, list additional account information in PART V, the narrative section.

PART II Suspect Information

Check the box if suspect information is not available;
Collect and record as much information as possible;
Place the information in the appropriate section of PART II;
Do not indicate "See PART V" or "See next Page";
Do not identify suspects by initials unless the full name is not known;
Always include street numbers and apartment numbers, if known;
Include the suspect's occupation if known or suspected;
Complete the Number and Issuing Authority section of block 29
- List the State that issued the DL or ID;
- List the Country that issued a Passport using standardized country codes;
- List the letter preceding the number on an Alien Registration card, along with the number.

The original version appeared in the September 2002 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 1/27/03