Question:
I have a SAR filing question, regarding NAICS codes. We have an internal Quality Assurance Department that reviews all SARs filed in our BSA/AML Department. We are being advised to apply NAICS codes based on the type of industry an individual is employed in; For example we have an individual that is employed as a SCHOOL NURSE – I believe the NAICS code should be 6213 “Office of Other Health Practitioners." However, my QA team is suggesting we use NAICS code 611 “Educational Services.”
Other Examples
Anesthesiologist with Conta Costa County we used 6213 “Office of Other Health Practitioners” – my Investigator was told to change this individuals NAICS code to 923 “Public Administration/Administration of Human Resource Programs, because the individual is employed with the County of Conta Costa. Or Accountant for New Beginnings we used 5412 “Accounting, Tax Prep” – my Investigator was told to remove 5412 and instructed to leave the NAICS code field blank because we could not definitively identify what type of business New Beginnings operates. I would greatly appreciate your interpretation or any reference materials like a previous FinCEN FAQ or SAR Activity Review Trends, Tips & Issues that would clarify or address this issue.