TO: |
CHIEF EXECUTIVE OFFICER |
SUBJECT: |
FinCEN Advisory - Preparation of Suspicious Activity Reports
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Attached is a copy of the Department of the Treasury's February
1997 issue of FinCEN Advisory, published by the Department's
Financial Crimes Enforcement Network (FinCEN). This issue is
devoted to guidance on preparing Suspicious Activity Reports
(SARs) to help eliminate errors and promote consistency in
reports filed.
In addition to the items addressed in the attached publication,
the FDIC has found two areas of the report often completed
incorrectly.
Item 14 (Date Closed) is intended primarily for use by the
regulatory agencies to indicate the date a financial
institution was permanently closed. Item 14 should not be
completed by open financial institutions.
The instructions for completing the SAR clearly indicate
that supporting documentation should not be included with
the report, because attachments are not entered into the SAR
database. However, financial institutions frequently write
"see attached" in Part VII, "Suspicious Activity Information
Explanation/Description," and attach documents to the
report. This section should, instead, contain a clear and
concise description of the activity that is being reported.
This will assist law enforcement in determining whether the
case needs further investigation and help eliminate
unnecessary contacts with the institution to determine the
reason for the report.
FinCEN Advisory is designed to keep financial institutions,
regulatory agencies and law enforcement agencies advised of
trends and developments related to money laundering and financial
crime. The periodical provides intelligence and analysis for
case support to federal, state, local and international law
enforcement and regulatory agencies, while furnishing financial
communities with the information they need to help prevent,
detect and report financial crime.
In a continuing effort to assist banks in Bank Secrecy Act
compliance, anti-money laundering efforts, and prevention and
detection of other financial crimes, the FDIC forwards each issue
of FinCEN Advisory to FDIC-supervised banks. Please circulate
copies to each department of your institution with Bank Secrecy
Act compliance and internal security responsibilities.
Comments about FinCEN Advisory should be addressed to the
Financial Crimes Enforcement Network, Office of Communications,
U.S. Department of the Treasury, 2070 Chain Bridge Road, Vienna,
VA 22182. Comments also may be faxed to FinCEN at (703) 905-3885.
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Nicholas J. Ketcha Jr. |
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Director |
Attachment:
http://www.fincen.gov/
Distribution: FDIC-Supervised Banks (Commercial and Savings)
NOTE: Paper copies of FDIC financial institution letters may be
obtained through the FDIC's Public Information Center, 801 17th
Street, N.W., Room 100, Washington, D.C. 20434 ((703) 562-2200 or
800-276-6003).
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