The Financial Crimes Enforcement Network (FinCEN), a department within the US Treasury, issued on October 10, additional guidance with respect to the filing of Suspicious Activity Reports (SARs). The guidance sets forth the 10 most common errors with respect to the filing of such reports and the means by which many of them can be mitigated.
Notably, FinCEN identified three distinct areas where financial institutions should concentrate their efforts to ensure the information in any SAR is complete: (i) SAR narratives, (ii) certain critical fields that allow users to analyze quickly where activity has occurred, and (iii) fields that identify type, category and character of the suspicious activity. Within those three areas, the guidance addresses issues such as inadequate or empty narrative fields, invalid subject social security number or employer identification number, and missing characterizations of suspicious activity.
The errors were noted by FinCEN in its review of SARs filed by money services businesses, but the agency stated in its release that this guidance has applicability to all institutions required to file SARs.