NEWS: The NCUA, along with the Financial Crimes Enforcement Network (FinCEN) and other federal agencies, announced the issuance of answers to four frequently asked questions about Suspicious Activity Reports (SARs). These answers clarify commonly asked questions by financial institutions about SAR rules to help enable them to focus resources on activities that produce the greatest value to law enforcement agencies. The questions address the topics of structuring, continuing activity reviews, timelines for continuing activity reviews and documentation for decisions not to file a SAR.
The answers to the new FAQs do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations, their aim is to provide clearer guidance and to simplify the SAR process.
- SAR Filings for Potential Structuring-related Activity
- Continuing Activity Reviews
- Continuing Activity Reviews – Timeline
- No SAR Documentation
As a reminder, credit unions are required to electronically file BSA reports, such as SARs, using FinCEN’s online BSA E-filing system. You can find additional information on the requirements for filing SARS in The League’s ii Release No. 0109. In addition, FinCEN provides this full list of FAQs to assist credit unions in their use of the FinCEN SAR. FinCEN will continue to issue additional FAQs and guidance as needed.