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Updated Definition for Suspicious Activity (SAR)

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Where can I find an updated definition guide for the suspicious activity categories of a SAR?

The last was published in the 7th Issue of the SAR Activity Review, in August 2004. It is still a very good reference.

The "legacy" SAR contained 20 check boxes, most of which were separate federal crimes. The 2004 guidance described most of them in practical terms and made it easier for bankers to understand what checking a specific box meant.

However, the electronic FinCEN SAR follows a completely different thought process. It has dozens and dozens of check boxes (I've resisted the urge to count them) some of which describe criminal acts, but many of which just relate factual information. Any guidance that would describe crimes like "structuring" or "wire fraud" would be unchanged since 2004. However, FinCEN would probably say that terms like "suspicious exchange of currencies" or "two or more people working together" are intended to be self explanatory and no guidance should be necessary.

Personal opinion, strongly held: The philosophy reflected in the "new" SAR was a significant error in judgment that eliminates some interesting information on SAR statistics. For example, two banks can have identical fact situations that prompt a SAR filing. One may check two boxes. The other, six. Any statistics produced by the filing of 800,000+ SARs reflect "number soup," nothing more.

First published on 02/19/2017

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