Thursday, May 29, 2014

What are Suspicious Activity Reports and Who Should File ?

The BSA also requires every US national bank to file a Suspicious Activity Report (SAR) when they detect certain known or suspected violations of federal law or suspicious transactions related to a money laundering activity or a violation of the BSA. A SAR filing is required for any potential crimes:
-          involving insider abuse regardless of the dollar amount;
-          where there is an identifiable suspect and the transaction involves $5,000 or more; and
-          where there is no identifiable suspect and the transaction involves $25,000 or more
An SAR filing also is required in the case of suspicious activity that is indicative of potential money laundering or BSA violations and the transaction involves $5,000 or more. A customer must not be informed that an SAR related to his transactions is being filed.
In the BSA/SAR context, a “transaction” includes any of the following:
-          a deposit
-          a withdrawal
-          a transfer between accounts;
-          an exchange of currency;
-          an extension of credit;
-          a purchase or sale of any stock, bond, certificate of deposit, or other monetary instrument or investment security; or
-          any other payment, transfer, or delivery by, through, or to a bank
The law requires the following institutions to file SARs:
-          Depository institutions
-          Money Service Businesses (MSBs)
-          Casinos and card clubs
-          Securities and futures industries
-          Insurance companies

-          Mutual fund operators

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