SAR Essentials – Current Requirements and Pending Changes
Recent enforcement actions have focused on a failure to identify, monitor, and report suspicious activity. The FFIEC BSA Exam manual states that “Suspicious Activity Reporting forms the cornerstone of the BSA reporting system." Does your financial institution have an effective SAR program that manages the reporting requirements? FinCEN announced revisions to the Suspicious Activity Report that do not create new regulatory requirements. However, the changes provide expanded and new options for reporting suspicious activity.
Learn important tips to help your financial institution avoid the FIVE issues that may cause violations with Suspicious Activity Reporting requirements. Review important deadlines and timeframes for the upcoming FinCEN updates that become available in June 2018. Here are some highlights of the webinar that are designed to help you manage the current requirements and prepare for the upcoming changes.
Overview of the five essential SAR requirements:
Identification or alert of unusual activity (which may include: employee identification, law enforcement inquiries, other referrals, and transaction and surveillance monitoring system output)
SAR decision making;
SAR completion and filing; and
Monitoring and SAR filing on continuing activity
FinCEN updated the SAR form and is making changes to the E-filing process. Highlights include:
Important deadlines and timeframes pertaining to the upcoming FinCEN updates
Understand what’s new for SAR requirements, including subtype selections
New text field to alert FinCEN that a SAR is being filed in response to a current GTO (Geographic Targeting Order), advisory or other activity;
Importance of a new "Cyber Event" suspicious activity type category;
New or modified options for Structuring, Fraud, Gaming Activities; Money Laundering; Identification/Documentation; and Mortgage Fraud;
New text fields for an IP Address
New product type selections
Batch filers will submit the updated SAR data in an XML based format, rather than the current ASCII-based fixed-length delimited file. The new SAR will be available on the BSA E-Filing System to discrete (single) filers sometime in June 2018. Batch filers with have six months after the yet-to-be-announced June “go-live” date to change over to the XML format. ASCII batch files will be accepted until January 1, 2019.
SAR checklist to Identify, Monitor, and Report Suspicious Activity based on BSA Exam Procedures and the Risk Assessment Process
Sample BSA Responsibility Matrix, including tasks for SAR monitoring.
Highlights of Appendix L (SAR Quality Guidance) and tips for documenting SAR decision making
The employees who will benefit from the program include new account staff, lenders and loan support staff, branch administration, deposit and loan operation staff, BSA Officers and staff, and trainers for the loan and deposit areas.
Susan Costonis is a compliance consultant and trainer. She began her banking career in 1978 and specializes in compliance management along with deposit and lending regulatory training.
Susan has successfully managed compliance programs and exams for institutions that ranged from a community bank to large multi-state bank holding companies. She has been a compliance officer for institutions supervised by the OCC, FDIC, and Federal Reserve. Susan has been a Certified Regulatory Compliance Manager since 1998, completed the ABA Graduate Compliance School, and graduated from the University of Akron and the Graduate Banking School of the University of Colorado. She regularly presents to financial institution audiences in several states.