THE WORKS Blog, Credit Union Compliance News & Views

      FinCEN’s Suspicious Activity Report Gets Enhanced

      By Marina Hernandez · Jun 01, 2018

      As you all know, new and updated data fields were added to the online Currency Transaction Report (CTR) last year and recently there was a deadline to meet a new format requirement for CTR batch files. The updates outlined in the Federal Register went live August 2017, but batch filers had nine months before fully transitioning to the new file format. It is June 2018, so here we are using the CTR’s new and updated fields and adhering to the requirement to submit batches in an XML-based file, rather than the previous ASCII fixed-length delimited file format.

      June 2018 is also the go-live date for FinCEN to update their Suspicious Activity Report (SAR) on the BSA E-Filing System, and adhere to changes defined in the Federal Register Notice posted on February 2, 2018. Online Suspicious Activity Reports (SARs) were patiently waiting in the wing, but you will see more changes this month on FinCEN’s website as this online report was also enhanced with new fields and features. Not to worry, you still have some time to update your SAR batch files in the new XML-based file since the BSA E-Filing System will continue to accept ASCII based batch files until January 1, 2019.

      Here are the updates you’ll see on the SAR beginning this month:

      1. New text field option: Filing institution note to FinCEN
      2. New/Modified types (and sub-types) of suspicious activities
      3. IP Address: Date and Timestamp
      4. New Cyber Event Indicators
      5. New Product Types
      6. New Types of Securities and Futures Institutions

      SAR Federal Register
      FinCEN Announcement on SAR Updates
      CTR Federal Register
      FinCEN Announcement on CTR Updates