When completing a SAR, when is it appropriate for a bank to indicate that it is a Paying Location or a Selling Location in Items 52 or 64? When is it appropriate to leave Items 52 or 64 blank?

FAQs associated with Part III of the FinCEN SAR

18. How do we complete Item 52/64 on the new FinCEN SAR which asks for the financial institution or branch’s “role in transaction,” and provides options for “Selling location,” “Paying Location,” or “Both”?

The new FinCEN SAR is a “universal” SAR as it combines elements from the various legacy SAR forms that FinCEN previously issued. While Items 52 and 64 were elements of the legacy “SAR-MSB,” they may be applicable to other types of financial institutions, providing useful information to law enforcement. Items 52 and 64 are non-critical fields, however, and only need to be completed if they are applicable to the activity being reported. As an example, if the activity being reported on the FinCEN SAR involved only the structuring of cash deposits, then a financial institution would not complete Items 52 or 64, as the institution was neither a “paying” nor “selling” location in the activity being reported. As another example, if the activity being reported on the FinCEN SAR involved unauthorized pooling of funds, then a financial institution would not complete Items 52 or 64, as the institution was neither a “paying” nor a “selling” location in the activity being reported.

On the other hand, if the activity being reported on the FinCEN SAR involved the suspicious purchasing of cashier’s checks by a customer, then a financial institution would check Item 40a “Bank/Cashier’s check,” and use Item 52 to indicate that the filing institution was the “Selling location.” If the sale of cashier’s checks included activity occurring at branch locations, then in completing the section for “Branch where activity occurred,” the financial institution would use Item 64 to identify the additional branches as “Selling location(s)” for the customer cashier’s checks. To add additional branches to the FinCEN SAR, click on the “+” icon to bring up additional sections in which to include the information related to those branches.

The “Webinar on the FinCEN SAR” located on the “Financial Institutions” homepage of www.fincen.gov provides additional examples of the appropriate use of these fields.

Condensed: It was on the MSB SAR where it made some sense, but nobody noticed it when we combined the reports. Even though we know it's totally irrelevant to the vast majority of SAR filings and will mean nothing to LEA's, we have come up with this answer rather than just saying it was a pure mistake on our part and that we will remove it the next time the CTR is revised .

What about for incoming/outgoing wires and other forms of EFT?

What about them? When was the last time you sold an incoming/outgoing wire and other form of EFT?