FINCEN DISCLOSES COMMON SAR MISTAKES

On October 10, 2007, FinCEN issued a statement titled “Suggestions for Addressing Common Errors Noted in Suspicious Activity Reporting.”  While the report does not propose any new requirements, it is intended to be informative and helpful for correcting some of the most common mistakes concerning SAR narratives and the entry of certain fields for analyzing where activity has occurred and fields that identify the type, category, and character of the suspicious activity.

Regarding SAR narratives  –  which ideally identify as fully as possible why the activity is suspicious – the most common mistakes are leaving the narrative field blank, attaching supporting documentation even though it is prohibited or else failing to fully describe the contents of the supporting documentation, and failing to supply adequate narratives.

Regarding the fields of critical value – which are examined by users to track activity and follow-up on leads and used by FinCEN to develop analytical products that are distributed to law enforcement – the common mistakes include failing to include specific special responses where required when data is unavailable (e.g., the entry, “N/A,” would be inappropriate in these particular fields where a specific response is desired) and failing to include such information as Employer Identification Numbers, telephone numbers, social security numbers or government issued identification.

Regarding the fields where the category and character of suspicious activity is identified, the common mistakes are failing to include the category, type, or characterization of the suspicious activity (otherwise, FinCEN cannot determine why the activity is being reported as suspicious) and providing an incorrect characterization of the suspicious activity.

A copy of the FinCEN statement can be reviewed here.