A Suspicious Activity Report (SAR) is a document that financial institutions must file with the Financial Crimes Enforcement Network (FinCEN) whenever a financial institution detects a potentially suspect transaction that may be indicative of financial crime. This may include but isn’t limited to, money laundering, fraud, or terrorist financing. Failure to report can result in penalties and fines for the financial institution.
The following situations may trigger a SAR:
- Unusual transactions or account activity
- Transactions over a certain value
- Domestic or international money transfers over a certain value
- Large cash deposits and/or withdrawals
The SAR functionality within Alloy's Case Management system streamlines compliance reporting and helps conduct due diligence, aggregate, export, and directly file suspicious activity reports with FinCEN. Alloy aggregates suspicious activity data, prefill key fields, subject, and transaction details, and validates this data before submission. A completed report can be directly filed with FinCEN, reducing manual data entry. The report can also be exported in a .txt or .xml format to share with the client's partner banks. Following the filing, clients can receive updates on the status of the filed reports, address feedback, and directly resubmit from the Case Management dashboard.
This article will cover the following sections:
- Permissions for SAR Filing
- Generating a SAR Filing
- Saving and Resuming Drafts
- Submission and Escalation
- Amended and Continuing Reports
- Report Statuses
- Downloading a Report
Permissions for SAR Filing
The following permissions must be enabled on an agent’s role for them to create a report and view past SAR filings. If any of these permissions are not enabled, the SAR Filing functionality may be limited or disabled.
Permission Category | Permission Name |
Case Management::Case Type | Agent can take action on all or specific cases, based on their types. |
Case Management | Agent can submit a report. |
Case Management | Agent can read and generate a report. |
Generating a SAR Filing
Before generating a SAR report, note that at any point, the SAR report can be saved as a draft by clicking Save Draft. If the report is exited without clicking Save Draft, the progress of the report will be lost.
- Navigate to Case Management from the side navigation
- Click on an open case in the queue.
- Click Take Action.
- Click Create Report. If you don’t see Create Report under the drop-down, it may be because a report already has already been started and saved as a draft. Click the draft in the case header to re-open the report. Read more about this in the Saving and Resuming Drafts section of this article.
- Once the report view is opened, in the Report Overview section, select the type of filing.
- Continue through the sections: Filing Institution Contact Information, Financial Institution Where Activity Occurred, Subject Information, and Suspicious Activity Information. Fill out each section of the SAR filing in its entirety with all requested or required information known to the filer. Submit as much information as possible, but make note that some fields are required and some are optional.
- In the Narrative step of the SAR filing, you can either Request a Review or Submit to FinCEN. Read more about these options in the Submission and Escalation section of this article.
Note: The report must be saved as draft at least once for the Submit to FinCEN button to be active.
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Once the report has been submitted, the report view will show “Report Finalized.” This means the report has been submitted and is locked. To update the report, a new report can created off of the report.
Saving and Resuming Drafts
A SAR report that has been generated does not need to be completed and submitted right away. Agents have the flexibility to save reports as drafts and return to them at a later time. Once a report has been generated, the Save Draft button is available on the top right.
Drafts can be resumed at any time by clicking into the report. To resume a draft,
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Find the Case in the Case Management queue. Click the Draft button under the Report Status column to open the report.
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Or click into the Case detail view of an open, and click the Draft button from the Case Header section to open the report.
Submission and Escalation
Once a report has been generated and filled out, an agent can either (1) Submit to FinCEN or (2) Request a Review.
- Submitting the report to FinCEN
Once the report has been submitted, the report will be locked and cannot be edited until FinCEN provides a response on the report status. It typically takes FinCEN about 48 hours to respond.
Agents will also receive emails from FinCEN confirming submission and updates on the report status.
Once a response is received, agents can file an Amended Report or Continuing Report.
- Escalating the report for review
The Request for Review button in the SAR filing process will reassign the SAR report to another agent to review. SAR filing workflows will often require that multiple agents review the SAR before filing to ensure completeness and clarity for the ultimate acceptance of the report.
If you have permission to generate a report, but not submit a report to FinCEN, you can use this option to reassign the case to an agent who can complete the review and submit the report.
By escalating for review, the entire case will be assigned to another agent. The Report Status will appear as “Ready for Review” so the report may be found in the My Cases queue.
Amended and Continuing Reports
Upon submitting an initial report to FinCEN, an agent can file two additional types of reports:
- Amended/Corrected: this can be filed if corrections are required by FinCEN or if there is additional information to provide on the initial activity.
- Continuing Activity Reports: institutions are obligated to review any activity that the report subject has in the 90 days following. If, during the 90 days post-submission, the customer continues to conduct suspicious activity, then the client has an additional 30 days to file a continuing activity SAR
Any subsequent reports that are created will be pre-filled with all of the information from the previous report. FinCEN uses BSA ID to connect reports to each other. Alloy will automatically pre-populate the previous report’s BSA ID to support filing requirements.
Report Statuses
The Case Management Queue includes specific statuses to indicate the state of a SAR report. These statuses can be seen under the Report Status column from the Case Management queue or in the Case Header within the Case view.
Alloy Status | Report Status | Definition |
---|---|---|
No Report | N/A | A report has not been generated for the case. |
Draft | N/A | A report has been generated and saved as a draft. The report is still open and can be resumed. |
Ready for Review | N/A | A draft report has been assigned to an agent for review. |
Submitted | Submitted | SAR filing submitted. No agent actions available. |
Processing | Processing | The report is being processed by FinCEN. No agent actions available. |
Action Required | Rejected Corrections Required | Agent can create new amended/continuing report or update amended/continuing report. FinCEN has indicated there are actions required on the report before it can be processed. |
Action Required | Accepted Corrections Required | Agent can create new amended/continuing report or update amended/continuing report. FinCEN has indicated there are actions required on the report before it can be processed. |
Accepted Corrections Unneeded | Accepted | Agent can create new amended/continuing report. |
Accepted Corrections Optional | Accepted | Agent can create new amended/continuing report. |
Finalized | N/A | Only available for Unusual Activity Reports (UARs). |
Downloading a Report
Whether a report is in draft status or submitted to FinCEN, the report can be downloaded at any time. Reports can be downloaded as a Text file or XML file.
- Navigate to a case.
- Click on the report.
- Click the More Options (three dots) menu on the upper-right side of the report.
- Select Download Report as Text or Download Report as XML.
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