![]() ![]() (3) Violations aggregating $25,000 or more regardless of potential suspects. If it is determined prior to filing this report that the identified suspect or group of suspects has used an alias, then information regarding the true identity of the suspect or group of suspects, as well as alias identifiers, such as drivers' license or social security numbers, addresses and telephone numbers, must be reported. Whenever the national bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank and involving or aggregating $5,000 or more in funds or other assets where the bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations or that it was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying a possible suspect or group of suspects. (2) Violations aggregating $5,000 or more where a suspect can be identified. Whenever the national bank detects any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted against the bank or involving a transaction or transactions conducted through the bank, where the bank believes that it was either an actual or potential victim of a criminal violation, or series of criminal violations, or that the bank was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying one of its directors, officers, employees, agents or other institution-affiliated parties as having committed or aided in the commission of a criminal act, regardless of the amount involved in the violation. The bank shall send the completed SAR to FinCEN in the following circumstances: A national bank shall file a SAR with the appropriate Federal law enforcement agencies and the Department of the Treasury on the form prescribed by the OCC and in accordance with the form's instructions. (3) SAR means a Suspicious Activity Report. (2) Institution-affiliated party means any institution-affiliated party as that term is defined in sections 3(u) and 8(b)(5) of the Federal Deposit Insurance Act ( 12 U.S.C. (1) FinCEN means the Financial Crimes Enforcement Network of the Department of the Treasury. This section applies to all national banks as well as any Federal branches and agencies of foreign banks licensed or chartered by the OCC. This section ensures that national banks file a Suspicious Activity Report when they detect a known or suspected violation of Federal law or a suspicious transaction related to a money laundering activity or a violation of the Bank Secrecy Act. The median reporting time for SARs in the FinCEN Files was 166 days (nearly half a year) since the suspicious activity started.(a) Purpose and scope. If more time is needed to identify a subject, 60 days. ![]() A SAR must be filed within 30 days once potential criminal activity is detected.Money-laundering, just like the crimes it tries to hide, is a crime. When criminals launder their dirty money, the “washing machine” that they use is the global financial system. This is disguising the source of illegally-obtained money, in an effort to make it appear legitimate. In FinCEN Files, the main trigger was suspicion of money laundering. What is the most common reason banks give for filing a SAR? Transactions by individuals known or suspected to have links to criminal or terrorist organizations.Odd dealings, like a diamond dealer paying a pizzeria for lingerie.Transactions linked to money laundering, terrorism financing or other crimes.The FinCen Files represent less than 0.02% of the SARs filed in the main period they cover. ![]() The Financial Crimes Enforcement Network (FinCEN) received more than 12 million SARs between 20 – and more than two million in 2019 alone. ![]()
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