Suspicious Activity Report
What is a SAR?
The Suspicious Activity Report or SAR is a key tool used by the government to help protect the nation from unlawful activities. There are different “flavors” of SARs for completion by different types of entities; MSBs file SAR-MSB forms.
When filing a report, you may not have all the facts. Rest assured that you are not declaring that the person is a criminal or involved in criminal activity. Those are facts to be determined by the authorities as confirmed by trials. You are simply identifying the person and transaction activity as suspicious. The experts will then use that information along with other information to make a determination whether additional investigation is needed.
It’s kind of like those dot/puzzle/art pictures that you need to stare at until you are cross-eyed to make sense of. They used to be all the rage at the malls. Stare long enough and the dots form a dinosaur or bird or something.
Your SAR filing (a dot), along with other CTR and SAR filings, and along with other data collections such as tax filings, create a picture. Your “dot” might even be the most important piece of the puzzle that makes the story come together. The law enforcement authorities connect the dots and take additional investigative actions based on the picture that emerges.
If, however, you have a situation where you can connect dots and believe that terrorist financing activities related to a potential terrorist attack against the United States may be occurring, you should call FinCEN immediately at 1-866-556-3974.
Often SARs have been instrumental in enabling law enforcement to initiate or supplement major money laundering or terrorist financing investigations and other criminal cases. Information provided in SAR forms also allows FinCEN to identify emerging trends and patterns associated with financial crimes. The information about those trends and patterns is vital to law enforcement agencies and provides valuable feedback to financial institutions and MSBs.
At various MSB and banking industry forums, members of the Federal Bureau of Investigation (FBI), the Immigration and Customs Enforcement (ICE) and other “customers” of the BSA data provided through SAR filings go out of their way to thank the industry for providing vital information through SAR filings. The filings have done and continue to do much to protect our communities from those who do or would do them harm.