Suspicious Activity Reports and filing Requirements

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