Alert July 21, 2009

FinCEN Announces that it will Provide Acknowledgements for Electronic Filings of SARs

The Financial Crimes Enforcement Network (“FinCEN”) announced that it will implement a system in September 2009 that will provide acknowledgements for suspicious activity reports (“SARs”) filed electronically by depository institutions, broker-dealers, investment companies, casinos, money service businesses and others.  The new functionality will give a document control number to those who file an SAR electronically as an acknowledgement of receipt for the originally submitted SAR.

FinCEN stated that its Bank Secrecy Act (“BSA”) E-filing system will allow filers to
self-enroll to receive SAR acknowledgements.  Furthermore, FinCEN said that in August 2009, it will make available an SAR acknowledgement questions and answers document.  SAR acknowledgements will not be provided to those who file SARs in paper form rather than electronically.  FinCEN also stated that in December 2009, it will implement SAR validations, which will “provide filers with feedback on the quality of their submission.”