We use nature of business and the 6 digit NAICS code to identify higher risk customers. Since the FinCEN list of limited acceptable NAICS Code of 2/3 digits was posted, front staff are asking Compliance to dumb down the list to something similar to FinCEN's.

Do other folks use anything less than the 6 digit code? My understanding is the 6 digit code considered the valid NAICS code and it helps us to identify higher risk customers.

Internally we use the full 6 digit code. Our core system gives us an error if the input is less than 6 digits.

The thing about FinCEN's list is that they are using it to collect very general statistics about CTR and SAR filings. Your bank wants to use it for idntifying high risk customers. A general coding like FinCEN's may not be conducive to what you are using NAICS codes for.

If you do batch efiling with NAICS codes in your CTRs, you'll need to ensure there is a good translation table that converts the code in your masterfile to a code that FinCEN will accept.

Thanks for the replies. We have the front line staff collect Nature of Business too, but sometimes the descriptions are vague. we are trying to find a balance since front line wants easy and simple...something BSA is not!

Dating back to 2005, we use the first 3-digits on all CIFs, (including 814 for personal & individual CIFs), which makes identification much easier and frankly more accurate for front-line users. We have provided two-sided reference guides for our staff to utilize in selecting the appropriate 3-digit code.

Hi Jennifer. Thanks for the reply. Would you be willing to share your guide with me?

Absolutely - PM me with your email address and I'll foorward what we use. The tool incorporates both NAICS coding as well as how we have defined Risk Rating Codes.