Alert! New SAR Line By Line
FinCEN has issued a notice to e-filers that announces an update to the Suspicious Activity Report (SAR) filing format, to go live in June 2018. The announcement says that the revisions adhere to the changes listed in FinCEN's February 2, 2017, Federal Register notice. Beginning with the new SAR filings, batch submissions will have to be made in an XML-based file, rather than in the current ASCII fixed-length delimited file format. Other notable changes:
- A new text field to alert FinCEN that a SAR is being filed in response to a current GTO, advisory or other activity
- A new "Cyber Event" suspicious activity type category
- New or modified subtype selections associate with Structuring, Fraud, Gaming activities, Money laundering, Identification/Documentation, Other suspicious activities, Securities/Futures/Options, and Mortgage fraud.
- New text fields with the IP Address field to record the date and/or timestamp of the first instance of the reported IP address
- New category of fields to record up to 99 cyber events associated with the suspicious activity
- New product type selections
- New subtype selections for securities and futures institutions
Discrete filers will start using the new online e-filing form in June 2018. Batch filers may start sending XML-format files with the revised fields beginning in June, but must complete their changeover to the new format within 6 months of the June "go-live" date. ASCII batch files will be accepted until January 1, 2019.