Skip to content
BOL Conferences
Thread Options
#2296433 - 04/25/24 03:51 PM SAR files as CTR
Auditgal Offline
100 Club
Joined: Dec 2014
Posts: 190
I am reviewing some SAR filings and I have not worked on the BSA Officer side where I have ever had to file a SAR or CTR. The BSA Officer e-filed the SAR apparently as a CTR (the e-file confirmation shows "submission type" as CTRX instead of SARX). I've reached out to FinCEN for an answer but that could take a while. Can anyone help me to know if FinCEN would have still received this in as a SAR or should they refile it as a SAR submission type?

Return to Top
BSA/AML/CIP/OFAC Forum
#2296462 - 04/26/24 01:58 PM Re: SAR files as CTR Auditgal
NatalieJ BSA Offline
Member
Joined: Apr 2016
Posts: 85
I don't know the answer to your question however, when a CTR or a SAR is filed, you are required to chose either FinCEN Report 112, which is the form for a CTR, or FinCEN Report 111, which is the form for a SAR. Those documents look very different in length and content. The first page of each report also indicates which BSA document it is. There is no place on a CTR to provide the information that is required for a SAR, so I can't think of any way in which your BSA officer could have filed a SAR on a CTR form.

Is is possible that the confirmation data you observed was linked to completed CTRs instead of completed SARs? Perhaps the wrong BSA confirmation numbers were recorded in the wrong place? Are there saved copies of the actual reports for you to review? Also, is your e-filing done as discrete or as batch filing? We only file discretely, so I have no experience to share about batch filing, which may look different when processing CTRs and SARs.

Return to Top
#2296467 - 04/26/24 03:05 PM Re: SAR files as CTR NatalieJ BSA
Auditgal Offline
100 Club
Joined: Dec 2014
Posts: 190
I had the BSA Officer walk me through it and basically he just goes into the FinCEN e-filing and selects attach file, attaches the SAR saved on his computer and clicks submit. He doesn't choose the type of submission. So somehow when FinCEN received it and did the confirmation they chose CTR type. The filing is a SAR and the confirmation sheet shows the correct name of the SAR. So I will wait and see what FinCEN says to do (if anything) when they call me. They do not batch file.

Return to Top
#2296500 - 04/26/24 08:49 PM Re: SAR files as CTR Auditgal
JennKK2 Offline
Gold Star
Joined: Nov 2006
Posts: 325
-
what??!!
_________________________
plan your Work and Work your Plan

Return to Top
#2296503 - 04/26/24 08:59 PM Re: SAR files as CTR Auditgal
rlcarey Online
10K Club
rlcarey
Joined: Jul 2001
Posts: 83,531
Galveston, TX
That is what I thought. smile I was not aware that you could file by uploading a copy of the SAR form.
_________________________
The opinions expressed here should not be construed to be those of my employer: PPDocs.com

Return to Top
#2296513 - 04/27/24 04:07 PM Re: SAR files as CTR Auditgal
Goldrose Offline
Member
Joined: Sep 2018
Posts: 67
That is how we discrete file now. It is just a single upload box, with your pin. You must submit the correct form. They used the wrong form, so without working at FinCEN I would say no, they have not filled the SAR officially. They filed an incorrect CTR, based on your statement that the “track Org” e-filling status is CTRX and not SARX.

Return to Top
#2296521 - 04/29/24 12:49 PM Re: SAR files as CTR Goldrose
NU Rhules Offline
Gold Star
NU Rhules
Joined: Mar 2011
Posts: 479
SE, Nebraska
Goldrose is correct, The person evidently entered SAR data on a CTR form. The forms are boldly labeled on page 1 as either a CTR or a SAR., so it looks like someone wasn't paying attention when they filled out the PDF. I'd be looking at their experience level, because I've never heard of this happening before. They will need to contact FinCEN and remove the bad CTR and properly report the SAR. They will have some explaining to do as well, as it is most likely now being filed late.
Auditor should be looking at the hard copy. It most likely is a CTR form.

Return to Top
#2296828 - 05/03/24 09:11 PM Re: SAR files as CTR NU Rhules
Auditgal Offline
100 Club
Joined: Dec 2014
Posts: 190
I received and reviewed the entire SAR on the SAR form. It was not a CTR (or a CTR transaction) - it was a SAR for Elder Financial Exploitation and the whole form was properly completed. The form was received by FinCEN and confirmed as a CTRX. I contacted FinCEN for the bank and FinCEN said that they did not receive a SAR (because it was assigned as a CTR clearly). I've instructed the bank to refile - question is if its initial or corrected, I guess. Probably Initial because it wasn't received by FinCEN as a SAR, but it does have a BSA e-filing ID (that starts with CX).

Return to Top

Moderator:  Andy_Z