The BSA also requires every US national bank to file a Suspicious Activity Report (SAR) when they detect certain known or suspected violations of federal law or suspicious transactions related to a money laundering activity or a violation of the BSA. A SAR filing is required for any potential crimes:
- Involving insider abuse regardless of the dollar amount;-
- Where there is an identifiable suspect and the transaction involves $5,000 or more;
- And where there is no identifiable suspect and the transaction involves $25,000 or more
An SAR filing also is required in the case of suspicious activity that is indicative of potential money laundering or BSA violations and the transaction involves $5,000 or more. A customer must not be informed that an SAR related to his transactions is being filed.
In the BSA/SAR context, a “transaction” includes any of the following:
- A deposit
- A withdrawal
- A transfer between accounts
- An exchange of currency
- An extension of credit
- A purchase or sale of any stock, bond, certificate of deposit, or other monetary instrument or investment security
- Or any other payment, transfer, or delivery by, through, or to a bank
The law requires the following institutions to file SARs:
- Depository institutions
- Money Service Businesses (MSBs)
- Casinos and card clubs
- Securities and futures industries
- Insurance companies
- Mutual fund operators