FinCEN Guidance on SAR Filings

by Mary Beth Guard, BOL Guru

FinCEN recommends that when it comes time for you to complete a Suspicious activity Report form you:

• Review the official completion instructions;
• Consult the additional guidance that has appeared in past issues of The SAR Activity Review;
• Call the FinCEN Financial Institutions Help Line at 1-800-949-2732 if you still have questions.

Soon, FinCEN plans to release a document entitled "Preparing a Complete and Sufficient Suspicious Activity Report" along with a PowerPoint presentation, "The Suspicious Activity Report and Keys to Writing a Complete and Sufficient SAR Narrative".

When you are filling out the narrative portion of the SAR, stick to the facts, but describe them in a manner sufficient to allow the stranger at FinCEN who has the good fortune to review your report to understand the true circumstances of the suspicious activity. Include all the details necessary to allow the investigators to establish any connections that may exist between the activity you are reporting and related suspicious activity which may be reported by someone else.

The original version appeared in the September 2003 edition of the Oklahoma Bankers Association Compliance Informer.

First published on BankersOnline.com 3/8/04