FinCEN Issues Notice On SARs Filing Figures

On May 26, 2020, the Financial Crimes Enforcement Network, ("FinCEN") issued a notice in the Federal Register updating cost estimates related to compliance with filing suspicious activity reports (SARs).  Under the Bank Secrecy Act, 31 U.S.C. § 5311 et seq., certain businesses providing financial services are required to file SARs upon suspicion that a crime or violation was committed by, at, or through that financial institution (so long as certain dollar thresholds are met), or upon suspicion of insider abuse of any kind.

Over the past several months, FinCEN has undertaken an extensive review of the costs associated with identifying potentially suspicious cases, reviewing case documents, and preparing and filing the resulting SAR.  FinCEN estimates, in general, that SARs can take anywhere from 20 minutes to several days to complete, based on the level of complexity involved, whether the SAR is an original or an update, and whether the firm is batch filing