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Completing the FinCEN SAR

Recorded on September 10, 2013

Proper SAR completion requires thorough, focused training as well as an understanding of how the form is used by law enforcement personnel.

WHAT?

This webinar focuses on how depositary institutions are to complete the FinCEN Suspicious Activity Report (SAR). SAR filing is required in regulations promulgated by the federal functional bank regulatory agencies as well as regulations interpreting the Bank Secrecy Act (BSA) issued by the Financial Crimes Enforcement Network.

WHY?

More than 860,000 SARs were filed in 2012. Regulators are increasingly focusing on "SAR quality" in their on site reviews. To top it all off, the form was substantially revised as part of FinCEN's IT modernization program. (The regulations requiring SAR filing did not change, only the report.)

This program describes how to properly complete the report and make it an effective vehicle for delivering information to law enforcement. It includes some discussion on how to write the SAR narrative and describe the supporting documentation. It also addresses the new "spreadsheet" tool incorporated into the report.

PROGRAM CONTENT

The presentation focuses on:

  • The FinCEN SAR FAQs
  • Filing triggers from FinCEN regulations
  • Filing triggers from regulatory agency regulations
  • Using case numbers
  • Identifying subjects
  • When to check multiple reasons for SAR filing
  • SAR narrative "key terms" what do they mean? When do we use them?
  • Proper SAR completion for continuing suspicious activity
  • Organizing the SAR narrative in chronological order
  • Addressing "Who, what, when, where, why & how" in the narrative
  • Facilitating law enforcement "data mining" operations in the narrative
  • Describing supporting documentation properly

This program does not deal with how to develop a SAR filing process. That issue is addressed in another webinar, "SAR Decision Making and Documentation."

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