SAR Filing Requirements: What Banks Don't Have to Do

Bank SAR Filing Requirements

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Question

When completing and filing a SAR, what is the bank NOT required to do?

Answers

Explanations

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A. B. C. D.

A

The term "CRCM" refers to the Certified Regulatory Compliance Manager certification offered by the Institute of Certified Bankers. In the context of the question, a SAR refers to a Suspicious Activity Report, which is a document that financial institutions are required to file with the Financial Crimes Enforcement Network (FinCEN) to report suspicious transactions that may indicate criminal activity.

Now let's review each answer option:

A. Submit a copy of the supporting documentation with the SAR: This statement is false. Banks are actually required to include supporting documentation with the SAR, including copies of relevant account statements, transaction records, and any other evidence that supports the report.

B. Submit the SAR within 30 days of the initial detection of facts: This statement is true. Financial institutions are required to file a SAR within 30 days of detecting suspicious activity or red flags indicating potential money laundering, terrorist financing, or other criminal activity. In some cases, an initial report may be filed within 60 days if additional time is needed to investigate the suspicious activity.

C. Report the SAR information to the bank's board of directors: This statement is partially true. Financial institutions are required to establish and maintain an effective anti-money laundering (AML) program that includes policies and procedures for filing SARs. The board of directors or senior management should be aware of the SAR filings and review the program's effectiveness periodically. However, there is no requirement to report the details of each SAR to the board of directors.

D. Maintain a copy of the SAR and supporting documentation for 5 years: This statement is true. Banks must keep a copy of the SAR and supporting documentation for at least five years from the date of filing. This requirement ensures that the institution has an adequate record of the suspicious activity and can produce the documentation if requested by regulatory authorities.

In conclusion, the correct answer to the question is A. The bank is required to submit supporting documentation with the SAR.