Tips from the Regulators

The following guidance is provided by the federal regulatory authorities and/or FinCEN.

Importance of having a Centralized Review of SARs

Financial institutions might consider establishing a centralized location for the review and processing of SARs. Nevertheless, as part of an institution?s internal controls, it is especially important that adequate management review of the SAR contents and filing is completed before the SAR is submitted. If a centralized review process is employed, financial institutions should ensure that the identity of the bank, its primary regulator, and the location of the transaction are clearly indicated on the SAR and that the SAR is not filed under the name and location of the centralized processing unit.

Also, when appropriate, the financial institution may wish to seek legal counsel during the filing process.

Excerpted from SAR Activity Review Issue 6, page 54