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Identifying the Category, Character and Subjects of Suspicious Activity

The following are examples of common errors received in the SAR fields identifying the type and the subject of suspicious activity being reported. Proper completion of these fields is important to more efficient analysis of BSA data. Information on possible characterizations of suspicious activity and their descriptions can be found in SAR Activity Review Issue 12.22

Subject/Suspect Information Unavailable. Filers should only check the box ?Subject/ Subject information unavailable? when there is no subject data that can be entered in the subject fields of the SAR.23 All subject fields should be left blank when this box is checked. When filers have partial subject data this data should be entered in the appropriate fields and the box left unchecked. SAR filers should then follow form instructions and FinCEN guidance when completing the remaining fields that have no data. For instance, instructions/guidance may require entry of an appropriate special response in some fields, while in others the requirement would be to leave the fields blank.

Using the Correct Form
Filing on expired or incorrect forms. Some filers continue to file SARs using expired versions of the correct form for their industry or on forms designated for other industries. Revised forms may contain changes designed to make the form more useful for users of the data, such as data fields that are not found on the expired version of the form. Likewise, forms designated for a specific industry make those forms more useful for users of the data by facilitating quicker identification and analysis of SARs. Filers should review the forms they are using to insure they are the correct and current version of the form for their specific industry.

Conclusion
Accurate and complete SARs provide users with important information that can be used to analyze broad sets of data and to apprehend suspected criminals and terrorists. Further, accurate and complete SARs documenting suspicious activity flowing through a financial institution allows that institution to identify potential risks, which may be of use in their AML program for risk mitigation purposes.


22 Issue 12 of The SAR Activity Review ? Trends, Tips and Issues is available at http://www.fincen.gov/news_room/rp/files/sar_tti_12.pdf#page=39.

23 The SAR-MSB form does not include this option.

Excerpted from SAR Activity Review Issue 16, page 51

First published on 10/01/2009

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