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Is Your Banking Compliance Team Ready for the SAR Transition?

Things to consider for the upcoming FinCEN SAR Updates
On 1st January 2019, the format and contents of Suspicious Activity Reports (SARs) filed with authorities in the US will change. It’s time to finalise your bank’s preparations for this switchover.
Recent FinCEN SAR UpdatesIn the New Year, SARs filed to the US Treasury’s BSA website will no longer accept electronic batch files in ASCII format. The Financial Crimes Enforcement Network (FinCEN) is updating the existing SAR form banks complete to SARX, which features new fields, a new Cyber type and the XML electronic batch file format. The deadline is fast approaching; it’s time to start thinking about a transition plan.
 
How will your team handle the ASCII to XML changeover? And what will the process be for the first Continued, Correct and Amend SARs in the new format?
 
 

 

Start thinking strategically:

Start thinking strategically about when to file those SARs with due dates that fall right before, during, and after the switchover date. FinCEN has advised that the Jan 1, 2019 deadline is a hard date; all SARs must be submitted in the XML format on that date and going forward. Consequently that also means acknowledgement files will be provided in the new XML format as of Jan 1, 2019 and afterwards. For example, if an electronic batch ASCII file is uploaded to BSA on December 31, 2018, when the corresponding acknowledgement file is returned on January 2, 2019, it will be in the XML, not the old ASCII, format.
 
Uploading the XML acknowledgement file to your SAR solution will probably not correlate to the previous ASCII format and the BSA Identifier number won’t sync up to the individual reported SARs. Now is the time to be formulating a plan for filing SARs in the ASCII format in order to get an ASCII acknowledgement file returned before switching over. Or, another option would be to start thinking about investigating the SARs but not creating and submitting SARs until after Jan 1, 2019, as long as that still keeps the SARs under the 30 day reporting deadline.
 
New fields are being added to the new report, and some fields are being removed. Certain types of Suspicious Activity may no longer be available for the Continued, Correct and Amend SARX from the Initial SARs that were filed in the ASCII format. On the other hand, investigators will have a few more suspicious types to choose from. The first Continued, Correct and Amend SARs in the XML format will have to be reviewed closely to ensure that the updated field changes are taken into account. Ensure that the SAR investigators are well versed on the pending changes so they know what to expect.
 

Use these last few months to:

  • Get well versed on the updates within the report, so your SAR investigators know what to expect. Use this ACAMS webinar which walks through all the changes and provides additional insights into the new cyber related activities.
  • Start thinking strategically about when to file those SARs with due dates that fall right before, during, and after the switchover date. 
  • Think through how to approach the differences for any Correct, Amend and Continued SARs that were generated from initial SARs with the different fields and older format.