Informal Value Transfer System Activity - Special SAR Form Completion Guidance for Reporting Potential

Financial institutions should be alert to the use of IVTS in the movement of funds linked to laundering of criminal proceeds or used to finance terrorism. The indicators of IVTS abuse for those purposes may be found in Section 2 ? Trends and Analysis, of this publication. If any financial institution knows or suspects that an IVTS is being used in illegal funds transfer, a SAR should be filed.

Specific Instructions for a Particular Industry

Financial institutions reporting any known or suspected criminal or terrorist-related activity conducted through IVTS on Form TD F 90-22.47 are requested to check the " Other" box in Part III, Line 35(s) of the form and note the abbreviation "IVTS" 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). If the activity involves terrorism and an IVTS, check the "Other" box in Part III, Line 35(s) and note the phrases, " Terrorism/IVTS" in the space following the box. Also, the narrative should include an explanation why the financial institution knows or believes an IVTS may be involved in the reported activity.

Financial institutions reporting any known or suspected criminal or terrorist-related activity conducted through IVTS on Form TD F 90-22.56 (MSB SAR) are asked to check the "Other" box in Part II, Line 28(d) on the form and note the abbreviation " IVTS" in the space following the box. However, in some situations, the suspicious activity may also involve money laundering and/or terrorist financing; therefore, the institution should also check Box 28(a) and/or Box 28(c). Additionally, the narrative should include an explanation why the financial institution knows or believes an IVTS may be involved in the reported activity.

Excerpted from SAR Activity Review Issue 5, page 57