A Suspicious Activity Report (SAR) is a filing with FinCEN when a financial institution detects activity that may indicate money laundering, terrorist financing, fraud, or other financial crimes.
When to File a SAR
SARs are required under the Bank Secrecy Act when:
- Transactions of $5,000 or more involve suspected illegal activity
- Any amount if terrorism is suspected
- Activity indicates potential violations of law
What SARs Contain
- Description of the suspicious activity
- Parties involved (subject information)
- Financial instruments used
- Why the activity is considered suspicious
- Supporting documentation references
SAR Confidentiality
Critical: SARs are confidential.
- Institutions cannot disclose to the customer that a SAR was filed
- Discussing SAR filings with the subject is prohibited ("tipping off")
- SAR information is shared with law enforcement
SARs and KYB
For KYB programs, SAR obligations mean:
- Suspicious business behavior during verification may trigger filing
- Ongoing monitoring that detects suspicious activity triggers SAR consideration
- SAR filing decisions are separate from relationship decisions (you may file a SAR and continue the relationship, or file and exit)
Filing
SARs are filed electronically through FinCEN's BSA E-Filing system within 30 days of detecting suspicious activity.
Related: FinCEN | BSA | CTR | AML
