Compliance blog examines SAR FAQs issued by FinCEN
The latest blog entry from America’s Credit Unions’ compliance team addresses the recent Financial Crimes Enforcement Network (FinCEN) FAQs, which clarify certain Suspicious Activity Report (SAR) requirements. FinCEN issued the FAQs in conjunction with the NCUA and other federal financial regulators last week to ensure financial institutions are only expending resources on efforts that aid law enforcement.
Because the banking regulators and NCUA issued these FAQs jointly with FinCEN (the ultimate regulatory authority on Bank Secrecy Act (BSA) compliance matters), these revised FAQs take precedence if there is any difference from preexisting regulatory guidance.
The blog expands on the following four FAQs:
- Is a financial institution required to file a SAR for a transaction or a series of transactions with a value at or near the currency transaction reporting (CTR) threshold (i.e., over $10,000) absent information that the transaction or series of transactions is designed to evade BSA reporting requirements?
- Is a financial institution required to conduct a review of a customer or account following the filing of a SAR to determine whether suspicious activity has continued?
- What is the timeline for a financial institution that elects to file SARs in accordance with FinCEN’s continuing suspicious activity guidance?
- Is a financial institution required to document the decision not to file a SAR?
Other recent Compliance Blog entries address the upcoming halt in penny production, and the intersection of state artificial intelligence laws, federal regulation, and credit union compliance.
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