Close

Suspicious Activity Reports

Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations

About Suspicious Activity Report Character Limits

Should financial institutions file additional SARs on the same suspicious activity to accommodate narratives that are longer than the SAR narrative character limits? No. Filers must provide a clear, complete, and concise description of the suspicious activity that led to the decision to file the SAR.13 A financial institution that […]

January 21, 2021

Read More

About Information in Data Fields and Narratives in SAR Reports

Does a financial institution need to repeat information in the SAR narrative that has already been included in other SAR data fields?   No. As stated in the SAR instructions, information provided in other sections of a SAR does not need to be repeated in the narrative unless necessary to […]

January 21, 2021

Read More

About SAR Monitoring on Multiple Negative Media Alerts

What if there are multiple negative news alerts based on the same event, is a financial institution expected to independently investigate each of those alerts? No. In circumstances where there are multiple negative news alerts (as identified through monitoring for unusual or suspicious activity) based on the same underlying events, […]

January 21, 2021

Read More

SAR Filing on Negative News Identified in Media Searches

Is a financial institution required to file a SAR based solely on negative news? No. The existence of negative news related to a customer or other activity at a financial institution does not by itself indicate that the criteria requiring the filing of a SAR have been met, and does […]

January 21, 2021

Read More

Requests by Law Enforcement for Financial Institutions to Maintain Accounts: Can financial institutions maintain an account or customer relationship for which it has received a written “keep open” request from law enforcement, even though the financial institution has identified suspicious or potentially illicit activity?

Yes. Law enforcement may have an interest in ensuring that certain accounts and customer relationships remain open notwithstanding suspicious or potential criminal activity in connection with the account. A financial institution may decide to maintain an account based on a written “keep open” request from a law enforcement agency, however, […]

January 21, 2021

Read More