Bank's Obligations When Filing a Suspicious Activity Report (SAR)

A

The Financial Crimes Enforcement Network (FinCEN) requires financial institutions to file Suspicious Activity Reports (SARs) to report any suspicious transactions or activities that may indicate money laundering, terrorist financing, or other criminal activities. Compliance with SAR filing requirements is a critical aspect of a bank's Bank Secrecy Act/Anti-Money Laundering (BSA/AML) program.

When completing and filing a SAR, a bank is required to fulfill several obligations. The correct answer to the question is (B) Submit the SAR within 30 days of the initial detection of facts.

Option A - Submit a copy of the supporting documentation with the SAR:

When filing a SAR, the bank is required to include all relevant and necessary information, including supporting documentation. The supporting documentation helps FinCEN understand the nature of the suspicious activity and determine whether further investigation is necessary. Therefore, the bank must submit a copy of the supporting documentation with the SAR.

Option B - Submit the SAR within 30 days of the initial detection of facts:

When a bank detects suspicious activity, it is required to file a SAR with FinCEN within 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a SAR. This time frame may be extended by an additional 30 days if the bank is unable to file the SAR within the initial 30-day period and the bank files a request for an extension with FinCEN before the original deadline.

Option C - Report the SAR information to the bank's board of directors:

When a bank files a SAR, it is not required to report the SAR information to its board of directors. However, the board of directors should be informed of the bank's overall SAR filing activity and the effectiveness of the bank's BSA/AML program. The bank's management should provide the board with regular reports that include, at a minimum, the number of SARs filed, the disposition of those SARs, and any SAR-related corrective actions taken by the bank.

Option D - Maintain a copy of the SAR and supporting documentation for 5 years:

When a bank files a SAR, it is required to maintain a copy of the SAR and supporting documentation for five years from the date of filing. This requirement helps ensure that the bank can produce the SAR and supporting documentation upon request by FinCEN or other regulatory agencies.

In summary, the bank is NOT required to submit the SAR within 30 days of the initial detection of facts (Option B) when completing and filing a SAR.