KeystoaWellPreparedSuspiciousActivityReport-FinCEN.ppt

Suspicious Activity Report This presentation is provided to educate financial institutions about the filing requirements and use of the Suspicious Activity Report. The Importance of Filing a SAR Identifies potential actual illegal activity: Financial Institutions Required To File SARs  Depository Institutions (since April ‘96) Money Services Businesses (MSBs) (Money trans-mitters issuers, sellers redeemers of money orders or travelers checks since January ‘02) (Currency dealers exchangers since March ’03 – effective Aug. ‘03) Casinos Card Clubs (since March ’03) Securities Futures Industries (Broker-Dealers since January ‘03) (Futures Commission Merchants Introducing Brokers in Commodities – effective May 18, 2004) Insurance Companies (proposed) Mutual Fund Operators (proposed) SAR Reporting Deadlines A financial institution is required to file a SAR: Depository Institutions Required To File A SAR Banks Savings Association Savings Association Service Corporations Credit Unions Bank Holding Companies Non-bank subsidiaries of bank holding companies Edge Agreement Corporations U.S. branches agencies of foreign banks Form to use: When Must A SAR Be Filed? For any known or suspected violations of federal criminal laws or regulations committed/attempted against or through the institution if it involves or aggregates at least $5,000 in funds or other assets the bank knows, suspects, or has reason to suspect the funds are: When Must A SAR Be Filed? For any known or suspected federal criminal violations committed/attempted against or through the institution involving funds (cont.): When Must a SAR Be Filed? MSBs Required to File a SAR Money Transmitters Currency dealers or exchangers Issuers, sellers, or redeemers of money orders Issuers, sellers, or redeemers of traveler’s checks Form to use: When Must a SAR-MSB Be Filed? Any transaction