Percentage of SARs Reporting Structuring

Field 35 of the SAR form.Summary Characterization of Suspicious Activity. does not break out BSA, Structuring or Money Laundering violations into separate check-off categories. As a result, it has been difficult to provide accurate estimates of the levels of the different types of suspicious activity reported under the catch-all BSA/Structuring/Money Laundering characterization. In particular, questions are frequently raised by both law enforcement and the financial industry concerning the percentage of SARs filed that involve structuring.

To better respond to these questions, FinCEN conducted an analysis of the national SAR database involving the extraction of a random set of 2,500 SARs for each year from 1996 to 2001. The subset of SARs in which the BSA/Structuring/ Money Laundering box was checked was then extracted. The narratives of these SARs were then analyzed to determine if structuring activity formed the basis for the report. The resulting set of SARs.those involving structuring.was used to establish sample percentages for structuring for each year. These samples can be extrapolated into estimates of the overall percentage of SARs reporting structuring. Results of this analysis are shown in the following table:


Voluntary SAR Filings

A small part of the total volume of SARs filed relates to reports filed voluntarily by brokers and dealers in securities who are not affiliated with banks; money services businesses; or gaming businesses that have no regulatory requirements at this time that mandate SAR filings. For the June 2001 Issue of the SAR Activity Review, at the request of the filing industries, FinCEN conducted a study to determine the number of SARs being filed voluntarily. The following table provides an update of findings relevant to voluntary SAR filings from April 1996 through April 2001.



15 Casinos that filed reports of suspicious activity on the bank SAR form. 16 Casinos located outside of Nevada (which has mandatory SAR requirements) and casinos located in New Jersey that filed SARCs prior to their October 12, 2000 mandatory SAR requirements went into effect. For the Casino Suspicious Activity Reports the reporting period is late 1997 through April 2001. 17 BSA/Structuring/ML percentage average does not contain violation(s) as reported on SARCs for same period.

Excerpted from SAR Activity Review Issue 3, page 25