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How to Report Suspicious Activities for Financial Institutions

Bankers are always asking how to practice due-diligence and file a Suspicious Activity Report (SAR) and not subject their bank and the directors to a lawsuit by disclosing confidential customer information. This, of course, is not new, but due to the Foreign Corrupt Practices Act (FCPA), this is very serious business. The privacy of a customers financial records is a hot topic and worth checking over the rules and the required balance between the customers interests and law enforcement concerns.

In 2000, the SAR form was revised and is easily downloaded from the Financial Crimes Enforcement Network. New Changes incorporate information concerning computer intrusions and there are more ‘check boxes’ for a more accurate completion.  Figuring out when to file a SAR, is a financial institutions priority. Always file when there is a discovery of Insider abuse no matter what the amount; violations aggregating $5,000 or more when a suspect can be identified, or aggregating $25,000 even if there is no substantial basis for identifying a suspect, any transactions aggregating $5,000 or more that involves a potential money laundering or the violations of the Bank Secrecy Act (BSA), and any computer intrusion.

The SAR filing requirements cover situations that financial institutions may suspect , know or has reason to suspect a transaction has occurred and involves receiving funds from illegal activities, such as evading BSA regulations by structuring transactions to involve less than the $10,000 currency threshold that requires filing a Currency Transaction Report, or a particular customer is doing business that is not the sort of in which they would normally be expected to engage. If $10,000 is exceeded, both the CTR and a SAR must be filed no later than 30 days after the initial detection of any of the above violations. But, a report can be delayed up to 60 days in order to identify a suspect.

Related posts:

1. Anti-Money Laundering Efforts in Tanzania
2. Outdoor Activities in Singapore

Tags: Financial Crimes Enforcement Network, Foreign Corrupt Practices Act, Suspicious Activity Report

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