This is the second part of a series that discusses regulatory reporting related to financial crimes in the United States.
- Part 1, Currency Transaction Reports and Designation of Exempt Persons
- Part 2, Suspicious Activity Reports
In a previous post, we learned that the Annunzio-Wylie Anti-Money Laundering Act in 1992 required financial institutions report activity that aggregates at least $5,000 by filing the Suspicious Activity Report.
When filing a Suspicious Activity Report, there are a multitude of data points that are being sent to FinCEN. The first step is identifying the type of filing.
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- Initial report
- This is the most common option and represents new suspicious activity.
- Correct/Amend prior report
- This option is available if a mistake was made in a previous report.
- Continuing activity report
- This option is for when this report involves suspicious activity that was previously reported but has continued. Reports should be filed at least every 90 days on continuing suspicious activity.
- You can read about continuing activity in this post
- Joint report
- Select this option if two financial institutions discover the activity together and are both being used for the activity.
- Prior report Document Control Number/BSA Identifier
- If b or c are checked, enter the identifier of previous report.
Next, there is an option to upload a .csv file as an attachment. This file would be used to document transaction records.
This was an amazing improvement in the reporting process. Can you imagine typing out "On 1/7/2023, the customer deposited $9,000 in cash to account 1 at branch North. On 1/9/2023, the customer deposited $9,000 in cash to account 2 at branch North. On 1/11/2023, the customer deposited $9,000 in cash to account 1 at branch South. On 1/12/2023, the customer deposited $9,000 in cash to account 2 at branch West." for several months of activity? I will tell you; it was a pain. I got to know how to concatenate in Excel really well!
In the Suspicious Activity Report, there are five parts that break down the Who, What, When, and Where.
Part I - Subject Information
In this section, you identify every known subject involved in the suspicious activity. This includes First, Middle and Last name of the person (or legal name of a business), Gender, Alternate names
Occupation (or type of business), Tax Identification Number, Date of Birth, Phone number, Email address, etc.
Part II - Suspicious Activity Information
In this section, you identify the total amount of the activity as well as the date range of the transactions. You select from a list of activity types to identify what you suspect is going on. For example, Structuring, Terrorist Financing, Fraud, Money Laundering etc.
Part III - Information about Financial Institution Where Activity Occurred
This section is specifically for the location of the activity. For example, a branch, an ATM, online, multiple locations as well as the address of each.
Part IV – Filing Institution Contact Information
This section records the financial institution, holding company, agency, or other entity that is filing the report. It includes the name of the financial institution, the TIN, who the regulator is, what type of financial institution it is, etc. This section also includes fields to identify if law enforcement was contacted, what agency, and the contacts name and number.
Part V - Narrative
This section is where you become a storyteller. This part is critical to someone reading it, so they understand the nature and circumstances of the suspicious activity. It is important to use full, complete sentences and no acronyms.
SAS Anti-Money Laundering makes completing and filing regulatory reports incredibly simple by storing all the relevant data for the investigator. To learn how to use SAS Anti-Money Laundering, you can take one of these e-learning courses
For more information about the SAS Anti-Money Laundering solution, please visit https://support.sas.com/en/software/sas-anti-money-laundering-support.html.
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