Voluntary SAR Filings

At the request of the filing industries, FinCEN conducted a study to determine the number of SARs being filed voluntarily. The initial review of the SAR database revealed that 15,139 SARs were filed by entities that appeared to fall outside of the mandatory reporting requirements. These SARs represented approximately 2.8 percent of all SARs filed for the period April 1, 1996 through December 31, 2000. For the period April 1, 1996 through December 31, 2000, casinos, using bank SAR forms, filed 55 reports. In addition, 1,062 suspicious reports were filed on the Suspicious Activity Report by Casinos (SARC form) by casinos located outside of Nevada (which has mandatory SAR requirements), as well as those filed by New Jersey prior to October 12, 2000 (mandatory SAR requirements for New Jersey went into effect October 12, 2000).

The initial database query was based upon the information provided in the filer field. In developing the statistics for this effort, a very broad array of search parameters was applied to identify those businesses that may be or are filing as non-depository institutions. The results were categorized by industry type such as: casino, credit/phone card services, insurance, mortgage services, money services business, realty (including property and real estate management), securities, travel, and miscellaneous.

Upon closer review, there was concern that a number of the filers identified as voluntary for the purposes of this study may have been affiliated with bank holding companies and thus subject to mandatory SAR reporting under the rules of federal banking agencies. A review of owner/subsidiary relationships confirmed that some of the filers initially identified as voluntary were in fact filed by institutions otherwise required to file. These filers were removed from the voluntary category.

The following table provides a summary of our findings relevant to voluntary SAR filings from April 1996 through December 2000.



Excerpted from SAR Activity Review Issue 2, page 19