Suspicious Activity Reports (SAR) (2024)

As of April 1, 2013, financial institutions must use the Bank Secrecy Act BSA E-Filing System in order to submit Suspicious Activity Reports.

A financial institution is required to file a suspicious activity report no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a suspicious activity report. If no suspect was identified on the date of detection of the incident requiring the filing, a financial institution may delay filing a suspicious activity report for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction.

Under the Bank Secrecy Act (BSA), financial institutions are required to assist U.S. government agencies in detecting and preventing money laundering, and:

  • Keep records of cash purchases of negotiable instruments;
  • File reports of cash transactions exceeding $10,000 (daily aggregate amount); and
  • Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion).

An amendment to the BSA incorporates provisions of the USA Patriot Act, which requires every bank to adopt a customer identification program as part of its BSA compliance program.

Learn More

Related News and Issuances

DateIDTitle
04/12/2021OCC2021-19Bank Secrecy Act/Anti-Money Laundering: Interagency Statement on Model Risk Management for Bank Systems Supporting BSA/AML Compliance and Request for Information
08/21/2020OCC2020-77Bank Secrecy Act/Anti-Money Laundering: Joint Statement on Bank Secrecy Act Due Diligence Requirements for Customers Who May Be Considered Politically Exposed Persons
12/03/2019NR 2019-141Agencies Clarify Requirements for Providing Financial Services to Hemp-Related Businesses
Suspicious Activity Reports (SAR) (2024)

FAQs

Suspicious Activity Reports (SAR)? ›

A Suspicious Activity Report (SAR) is a document that financial institutions, and those associated with their business, must file with the Financial Crimes Enforcement Network (FinCEN) whenever there is a suspected case of money laundering or fraud.

What are two triggers for a suspicious activity report SAR? ›

Some examples of suspicious activities that may trigger a SAR include:
  • Unusually large cash deposits or withdrawals.
  • Frequent transactions just below the reporting threshold to avoid detection.
  • Structuring transactions to avoid triggering regulatory requirements.
  • Rapid movement of funds between multiple accounts.

What does SAR report? ›

Your Student Aid Report (SAR) is an electronic or paper document that gives you some basic information about your eligibility for federal student aid. It also includes your answers to the questions on the 2023–24 FAFSA form.

Under which circ*mstances is a suspicious activity report SAR submitted? ›

A SAR should be submitted if a party has suspicion or knowledge of money laundering or terrorist financing, regardless of the amount or currency of a transaction.

How much money triggers a SAR report? ›

Under 12 CFR 21.11, national banks are required to report known or suspected criminal offenses, at specified thresholds, or transactions over $5,000 that they suspect involve money laundering or violate the Bank Secrecy Act.

What is considered suspicious activity? ›

What is Suspicious Activity? Suspicious activity is any observed behavior that may indicate pre-operational planning associated with terrorism or terrorism-related crime.

What are red flags that may trigger filing a SAR? ›

Common red flags include: Unusual transactions: Transactions that are unusual for a customer's profile, such as a large cash deposit or withdrawal from an account that has not previously made such transactions.

What is an example of a suspicious transaction? ›

high volumes of transactions being made in a short period of time. depositing large amounts of cash into company accounts. depositing multiple cheques into one bank account. purchasing expensive assets, such as property, cars, precious stones and metals, jewellery and bullion.

What would trigger a SAR investigation? ›

Dollar Amount Thresholds – Banks are required to file a SAR in the following circ*mstances: insider abuse involving any amount; transactions aggregating $5,000 or more where a suspect can be identified; transactions aggregating $25,000 or more regardless of potential suspects; and transactions aggregating $5,000 or ...

Who is responsible for filing a suspicious activity report in SAR? ›

The SAR is filed by the financial institution that observes suspicious activity in an account. The report is filed with the Financial Crimes Enforcement Network, or FinCEN, who will then investigate the incident.

What is a common reason to file a suspicious activity report? ›

An SAR is a document that financial institutions must file with the Financial Crimes Enforcement Network (FinCEN) as soon as they detect a suspected case of money laundering or fraud. SARs are an important tool for law enforcement to detect and investigate financial crimes.

How do banks detect suspicious activity? ›

Banks leverage sophisticated rule-based detection systems that monitor transaction patterns and flag anomalies. These systems analyze factors such as transaction frequency, amount, and geographical location, comparing them against established customer profiles and historical data.

What happens after a SAR is submitted? ›

This starts the next working day after you file your report. Once you've submitted your report, it will be processed and checked against law enforcement databases. If an investigation is needed, your SAR will be sent to the appropriate law enforcement agency.

Can you be sued for filing a SAR? ›

Can a money services business be sued by its customer for filing a suspicious activity report? The Bank Secrecy Act contains a broad protection from liability for making reports of suspicious activity, whether such reports are required by the rule or made voluntarily.

Is depositing $2000 in cash suspicious? ›

As long as the source of your funds is legitimate and you can provide a clear and reasonable explanation for the cash deposit, there is no legal restriction on depositing any sum, no matter how large. So, there is no need to overly worry about how much cash you can deposit in a bank in one day.

Can you talk about the fact that you filed a SAR? ›

Despite the fact many credit unions file SARs regularly, they are not allowed to talk about them – federal laws and regulations impose strict confidentiality rules relating to SARs.

What causes a SAR report? ›

If a customer does something obviously criminal – such as offering a bribe or even admitting to a crime – the law requires you to file a SAR if it involves or aggregates funds or other assets of $2,000 or more.

What is a common reason to file a SAR report? ›

Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion).

Which two things could be determined as suspicious Behaviour '? ›

Suspicious behaviour
  • Loitering in restricted or public areas.
  • Paying significant interest to entrances, exits, CCTV or security staff, taking photos.
  • Concealing face / identity.
  • Asking unusual or security related questions.
  • Avoiding security staff.
  • Activity inconsistent with the nature of the building or area.

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