FinCEN Offers Clarification in Suspicious Activity Filing Deadline for Continuing Activity

The Financial Crimes Enforcement Network (“FinCEN”) has released the SAR Activity Review Trends, Tips and Issues: Issue 21(“SAR Activity Review”) that focuses on trends and issues related to Money Service Businesses (“MSBs”) and updated rules on definitions and other regulations for pre-paid access as a component of MSB activity. A significant portion of the SAR Activity Review describes the statistics and trends related to FinCEN’s attempt to collect information on the MSB sector. FinCEN also restates the responsibilities that financial institutions have in reporting suspected unregistered or unlicensed MSB activity through SAR filing.

The SAR Activity Review also provides clarification on SAR filing deadlines for continuing activity. FinCEN says there has been uncertainty as to whether ongoing activity SARs should be filed every 90 or 120 days (30 days after the 90-day review). FinCEN states that its intent has been for financial institutions to file a continuing SAR after a 90-day review, with the filing deadline being 120 days after the date of the previously related SAR filing. However, financial institutions may file SARs on continuing activity earlier than the 120-day deadline if the institution believes the activity warrants an earlier review by law enforcement.

To discuss how PYA can assist your financial institution with your BSA program, please contact the expert listed below at PYA, (800) 270-9629.

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Read theSAR Activity Review Trends, Tips and Issues: Issue 21

WE ARE REQUIRED BY IRS CIRCULAR 230 TO INFORM YOU THAT THE FOLLOWING DISCUSSION WAS NOT INTENDED OR WRITTEN TO BE USED, AND IT CANNOT BE USED, NOR RELIED UPON, BY ANY TAXPAYER FOR THE PURPOSE OF AVOIDING ANY PENALTIES THAT MAY BE IMPOSED UNDER FEDERAL TAX LAW. THE ADVICE WAS WRITTEN TO SUPPORT THE PROMOTION OR MARKETING OF THE TRANSACTIONS OR MATTERS ADDRESSED IN THE DISCUSSION. EACH TAXPAYER SHOULD SEEK ADVICE BASED ON ITS PARTICULAR CIRCUMSTANCES FROM AN INDEPENDENT TAX ADVISOR.


Mike Shamblin

Mike Shamblin

Managing Principal of Audit & Assurance Services

Matt Stuart

Matt Stuart

Principal

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