by Elva M. Coffey-Sears, CRCM, CRP
FinCEN announced that the changes to the Suspicious Activity Report (SAR) proposed in February 2017 will be implemented and effective in June 2018. The revisions do not impose any new regulatory requirements nor change the requirements relating to suspicious activity reporting. FinCEN is removing, revising and adding new fields and changing the required format for data submission.
The SAR 2018 update includes:
- New text field for reporters to advise FinCEN that the SAR is being filed in response to a specific geographic targeting order, advisory, or other activity.
- New “Cyber event” suspicious activity type category, including indication of target – financial institution, financial institution customer, or other.
- New or modified subtype selections for the following categories of suspicious activities: Structuring; Fraud; Gaming Activities (Casinos); Money Laundering; Identification/Documentation; Other Suspicious Activities; Securities/Futures/Options; and Mortgage Fraud.
- New text field to record the date and/or timestamp of the first instance of a reported IP address.
- New category fields to record up to 99 cyber events associated with the suspicious activity, including: Command & Control IP address; Command & Control URL/Domain; Malware MD5; Malware SHA-1; Malware SHA-256; Media Access Control (MAC) Address; Port; Suspicious e-mail address; Suspicious filename; Suspicious IP address; Suspicious URL/Domain; Targeted system; and Other.
- New type selections for Deposit Accounts and Microcap Securities product types.
- New subtype selections associated with the types of securities and futures institutions.
The new online form will be available for discrete filers in June 2018. Batch filers are provided until January 1, 2019 to meet the new required XML specification.
FinCEN’s notice is available in the Hot Topics section of the BSA E-Filing System site. The February 2017 proposal can be viewed at: https://www.federalregister.gov/documents/2017/02/02/2017-02235/proposed-collection-comment-request-update-and-revision-of-the-fincen-suspicious-activity-reports
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