SAR Filing Tips for MSBs

The MSB SAR requirement became effective on January 1, 2002, and requires that certain MSBs, (i.e., money transmitters, issuers, sellers, and redeemers of traveler's checks, and issuers, sellers, and redeemers of money orders) report suspicious transactions occurring on or after January 1, 2002.

The following tips are provided for MSBs submitting SARs on the interim SAR form, TD F 90-22.47. These tips are being provided based on a review of the interim forms submitted by MSBs since January 1, 2002.

• MSBs should file a SAR only if the transaction is suspicious.
• MSBs must file a SAR if the transaction is suspicious and exceeds $2,000 ($5,000, if a clearinghouse).
• If the transaction is suspicious but does not exceed $2,000, the MSB may file a SAR voluntarily.
• If a SAR is filed, it is critical that Part V of the form (Suspicious Activity Information Explanation/Description) be completed to explain why the activity is considered suspicious.
• FinCEN has developed a SAR form18 to be used soley by money transmitters and issuers, sellers and redeemers of money orders and traveler's checks when reporting suspicious transactions. It is expected that this form will be available for use by October 1, 2002. However, in the interim, these MSBs should continue to use Form TD F 90-22.47 (bank SAR form) to report suspicious activities. NOTE: MSBs should write the letters "MSB" in block print at the top of the form and also in the blank space in Item 5 of the form. This will help to distinguish MSB SARs from SARs filed by depository institutions.

Excerpted from SAR Activity Review Issue 4 , page 42