SAR Filing – Common Problems and How to Navigate Proper Filing

The accuracy and comprehensiveness of SARs are crucial for law enforcement agencies to investigate and prevent financial crimes, and there are a few pitfalls that teams should be aware of to ensure that law enforcement can do its job effectively.
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Aaron Middleton

September 8, 2023

Suspicious Activity Reports (SARs) are a vital tool in the fight against financial crimes. Financial institutions and other entities submit SARs to the Financial Crimes Enforcement Network (FinCEN) when they detect potentially illicit activities. Failure in SAR filing can attract regulatory sanctions, expose you to legal risks, and critically damage your organizational credibility. The accuracy and comprehensiveness of these reports are crucial for law enforcement agencies to investigate and prevent financial crimes, and there are a few pitfalls that teams should be aware of to ensure that law enforcement can do its job effectively.

Lack of Complete Documentation or Data

First, submitting a SAR based on incomplete or insufficient investigation is unhelpful to law enforcement. A filer must ensure that they have thoroughly investigated and documented suspicious activities before filing a SAR. Rushing to file without proper due diligence can lead to false positives, wasting valuable time and resources.

Proper documentation is essential when submitting a SAR. This includes maintaining a record of the investigation, all relevant transaction data, and any communications related to the suspicious activity. Inadequate documentation can result in difficulties when law enforcement seeks additional information or clarification.

Using Old or Inaccurate Data

Incomplete, inaccurate, or outdated data can hinder the effectiveness of a SAR. Teams should ensure that their data sources are reliable and up-to-date, and have mechanisms in place to correct errors. Poor data quality can lead to missed opportunities to identify and combat financial crimes.

Regulatory Deadline Non-Adherence

Ramifications for Compliance Metrics

Failing to adhere to regulatory deadlines for SAR filing is akin to pulling the pin on a compliance grenade—it’s bound to blow up. The non-adherence doesn’t merely result in administrative snags; it cascades into severe consequences for your overarching compliance metrics. It corrupts your key performance indicators (KPIs), undermining both short-term and long-term strategies aimed at achieving and maintaining regulatory compliance. These missed deadlines can trigger fines, sanctions, and even investigations that can jeopardize your financial integrity. This all translates into eroded stakeholder trust and elevated operational costs to fix the ensuing mess. In this high-stakes game, time isn’t just money; it’s the lifeblood of your compliance ecosystem.

Proactive Management Techniques

Deadlines shouldn’t be the ticking time bombs of your compliance agenda. They should be managed seamlessly, almost effortlessly, through proactive techniques that integrate with your operations. The antidote to the chaos of regulatory deadline non-adherence is the adoption of an advanced compliance calendar. Imagine an algorithmically-driven calendar that doesn’t merely remind you but can enact predefined workflow mechanisms to mobilize your team into action. Leveraging automated notifications and task assignments, this calendar can keep key personnel in the loop in real-time. It acts as a preventative control measure, creating a safety net that acts before a deadline slips through the cracks. So, if you’re serious about compliance—and you should be—it’s high time to invest in automated, proactive management techniques that help you navigate the labyrinthine landscape of regulatory deadlines.

Lack of Context

One of the most significant pitfalls when creating a FinCEN SAR is failing to provide sufficient context. A SAR should not be just a collection of transaction data. It should also include a clear narrative explaining why the activity is suspicious. Failing to provide context can result in law enforcement struggling to understand the significance of the reported activity.

Over Reporting

While reporting suspicious activities is essential, over-reporting mundane transactions can create unnecessary noise and strain on financial institutions and law enforcement agencies. It’s critical to strike a balance between being overly vigilant and casting reasonable suspicion. Filing SARs for every minor anomaly can overwhelm the system and dilute the impact of genuinely suspicious reports. Finding a balance can come with experience or mentorship from more experienced team members.

Failing to Keep Up with Regulations

Financial regulations and reporting requirements can change over time. Failing to stay updated on these changes can lead to non-compliance and regulatory penalties. Teams should establish a process for regularly reviewing and adapting their SAR filing procedures to align with current regulations.

Lack of Training

Financial institutions must invest in ongoing training for staff responsible for SAR filings. Without proper training, employees may miss critical red flags, misunderstand regulatory requirements, or make errors that can have legal and financial repercussions that can be detrimental to the organization and broader society.

While SAR filing can feel like a complex task, with training, experience, and the right tools, a filer can learn how to correctly identify activity that should be reported and the best ways to document it to assist law enforcement with their investigating the suspicious activity. Effectiv offers an advanced BSA filing solution that works with our case management system to assist filers in their research by providing information from world-class data providers. It makes SAR filing easy by pre-filling reports with case data, standardizing organizational data across cases, ensuring that report information conforms to FinCEN standards, and directly filing the report with FinCEN, all within the same platform.

Speak to an Effectiv representative today for more information about our BSA filing solutions!

What’s next?

At Effectiv, we recently released our own in-house BSA filing solution aimed at helping teams to create reports more efficiently. Starting with SARs, we have crafted a modern, more friendly experience than what most reporters are used to.

We have painstakingly recreated the well-known SAR report into a sleek, modern UI and added time-saving features such as the ability to standardize and pre-fill institutional information across all reports, import data from our case management system, and validate information on the fly to ensure that reports contain the proper information. We package these reports into XML files that can be easily uploaded into the BSA E-File system, saving teams hours daily.

Keep on the lookout for more compliance tools coming soon, and contact one of our team members if you are interested in taking advantage of our modern SAR Filing solution.

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