New SAR Filing Requirements

The Financial Crimes Enforcement Network (FinCEN) recently made some changes to its Suspicious Activity Report (SAR) filing requirements that will likely impact an IB’s AML program. Specifically, beginning July 1, 2012, any financial institution, including an IB, filing a SAR must do so electronically through FinCEN’s BSA E-Filing System. According to FinCEN, E-Filing will enhance the quality of FinCEN’s electronic data, improve its capabilities in supporting law enforcement and increase cost efficiencies. There is no charge for using the BSA E-Filing System. FinCEN has indicated, however, that firms that file a SAR in paper form after the July 1 deadline…

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