What if I suspect “terrorist” activity?
Some suspicious transaction activities require immediate attention and immediate action.
If a money services business has reason to suspect that a customer’s transactions may be linked to terrorist activity against the United States, the MSB should immediately call the Financial Institutions Hotline, toll-free at: 1-866-556-3974.
If an MSB knows of other suspected violations of law that need immediate attention, such as ongoing money-laundering schemes, the MSB should notify the appropriate law enforcement agency, e.g. the local police, FBI, or IRS criminal investigations division.
In any case, an MSB must also file a SAR if it is subject to mandatory reporting; a phone call or visit with the authorities is not sufficient to meet the reporting requirement. (If not subject to mandatory reporting, the MSB should also file a SAR providing information about the suspicious activity and maintain records valuable to any subsequent investigation.)