Regulatory Alerts2012-03-29
Guidance on Filing FinCEN’s New Currency Transaction Report and Suspicious Activity Report
The Financial Crimes Enforcement Network (FinCEN) has begun accepting new Currency Transaction Reports (CTR) and Suspicious Activity Reports (SAR) through the BSA E-Filing System, replacing legacy forms until March 31, 2013. This guidance clarifies that the new electronic reports do not create new filing obligations or change existing statutory requirements, while detailing technical specifications such as critical fields, narrative character limits, and the allowance of CSV attachments. FinCEN also addresses specific data elements including gender, NAICS codes, and internet presence, noting a temporary 25-day filing window for CTRs to allow institutions time to adjust their processes.
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