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