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Reporting Potential Terrorist Related Activity on a SAR

General Instructions for Completing the SAR

FinCEN has received a number of calls from financial institutions requesting assistance in completing a SAR when the suspicious activity may be terrorist related. The following guidance is offered: 1) report the information on the SAR accurately and completely; and 2) complete the narrative section by describing the suspicious transaction as completely as possible and include the following information, if applicable - any correspondent bank name/account information; names/ locations of business entities; names of cities, countries and foreign financial institutions linked to the transaction, especially if funds transfer activity is involved; and account numbers and beneficiary names.

Specific Instructions for a Particular Industry

Financial institutions reporting potential terrorist-related activity on Form TD F 90-22.47 are requested to check the "Other" box on Part III, Line 35(s) of the form and note the word "terrorism" in the space following the box. However, in some situations, the suspicious activity may also involve money laundering, therefore, the institution should also check Box 35(a).

Casinos and card clubs reporting potential terrorist-related activity on Form TD F 90-22.49 (SARC) are asked to check the "Other" box on Part III, Line 32(n) and note the word "terrorism" in the space following the box. If the suspicious activity also involves money laundering, Box 32(h) or 32(j) should also be checked.

Regardless of which form is used, all filers should ensure that the narrative includes as much detail as possible regarding the potential terrorist-related and money laundering activities.

Excerpted from SAR Activity Review Issue 4 , page 41

First published on 08/01/2002

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