Does anyone happen to remember a few years back when FinCEN issued guidance in regards to narrative key words that should be used when filing SARs for certain activity? I know they will recommend key words in specific guidances, but I'm almost positive they issued a spreadsheet type document that listed all of the key words for SARs. Can somebody please help?

This is the only one I could find:

http://www.fincen.gov/news_room/advisory/AdvisoryKeyTerms.html

Doug, you are an angel! Talk about feeling like a goober....I've spent an hour looking for that!! Cannot say thank you enough!

My pleasure. You can actually thank BOL! They had a conference(?) on Smart Strategies and one of the things I learned was how to use the Google Advanced Search function to really hone in on what you want to find on the net; along with some other great tips, tricks and techniques.

FinCEN apparently publishes updated versions of this Advisory at will, automatically deleting previous versions from their web site. The most recent version I had was February, 2013. (Thanks for linking the current version.) My version no longer appears on the web site any more than the version Jessesgirl saw "a few years back" does. So, finding either would have been nearly impossible. FinCEN does not provide any notice that a revision has been published. Understandably, most of the bankers I've shown this to over the years had no idea of its existence anyway.

One purpose for using key terms is to make the SAR data base more readily searchable by both law enforcement and FinCEN personnel performing statistical analyses. They want SAR filers to use these key terms in the narrative. Also, if there is no equivalent check box in 29 - 38, they also want you to check "Other" and type in the key term.

On the legacy SAR none of the "key terms" had their own check box. On the FinCEN SAR, some do; e.g. "financial exploitation of the elderly," and "account takeover." So, the guidance makes a tad less sense than it did at one time, but still works for terms like "funnel account" and "tax refund fraud," etc. where there is no check box on the report.

My suggestion, not necessarily FinCEN's, is that if you have checked a box in 29 - 40 the word or words it includes should be conspicuously mentioned in the narrative no matter what.

Good point about the timing of their updates. The Human Trafficking guidance is noticeably absent. It'd be nice if FinCEN were to update this right as they release any guidance concerning keywords, it's very useful.

Sort of like waiting for the FDIC to update the regs on their site?

Exhuming this as FinCEN has added some key terms to the Advisory. I am not adding a new link, because the link Doug provided is still good. (As noted, the URL does not change when the Advisory is updated.)

Please note, however, that as of this moment, the date on the Advisory, May 28, 2014, is unchanged even though it contains terms from FIN 2014-A008 which was actually published 2 months later.

The content is correct, it's just that the list has been updated more recently than the date shown.