Words You Must Never Use

But only in Suspicious Activity Reports (“SARs”) and Currency Transaction Reports (“CTRs”)

The Financial Crimes Enforcement Network (“FinCEN”) is a bureau of the U.S. Department of the Treasury.  FinCEN’s mission is to safeguard the United States financial system from illicit use and combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities.

FinCEN exercises regulatory functions primarily under the Currency and Financial Transactions Reporting Act of 1970, as amended by the USA PATRIOT Act of 2001, commonly referred to as the Bank Secrecy Act (“BSA”).  The BSA is our nation’s most comprehensive Federal anti-money laundering and counter-terrorism financing (“AML/CFT”) statue.  The BSA authorizes the Secretary of the Treasury to issue regulations requiring banks and other financial institutions to take a number of precautions against financial crime, including the establishment of anti-money laundering (“AML”) programs and the filing of reports that have been determined to have a high degree of usefulness in criminal, tax, and regulatory investigations and proceedings, and certain intelligence and counter-terrorism matters.

In October 2012, FinCEN issued two guidance documents:

The purpose of the two documents is to provide the requirements and conditions for electronically filing the SAR Report and the CTR Report.  Embedded deep inside both documents, FinCEN warned that certain words must never be used when covered institutions, companies and individuals complete the forms.

For the Suspicious Activity Report, the listing of prohibited words is prefaced by the warning, “Do not use the following words or variations of these words in text fields, other than in Part V”

1. AKA

2. COMPUTED GENERATED

3. CUSTOMER

4. DBA

5. NON CUSTOMER

6. NONE

7. NOT APPLICABLE

8. OTHER

9. SAME

10. SAME AS ABOVE

11. SEE ABOVE

12. SEE NARRATIVE

13. SIGNATURE CARD

14. T/A

15. UNKNOWN

16. VARIOUS

17. XX

For the Currency Transaction Report, the prohibited words which are listed in the separate instructions and prefaced by the warning “Do not use the following words or variations of these words in fields.”  FInCEN did not include two words that the SAR prohibits which are “T/A” and “SEE NARRATIVE”:

1. AKA

2. COMPUTED GENERATED

3. CUSTOMER

4. DBA

5. NONE

6. NOT APPLICABLE

7. NON CUSTOMER

8. OTHER

9. SAME

10. SAME AS ABOVE

11. SEE ABOVE

12. SIGNATURE CARD

13. UNKNOWN

14. VARIOUS

15. XX

The mandatory BSA E-Filing allows organizations or individuals to electronically and securely file discrete and batched BSA forms.  FinCEN also utilizes the BSA E-Filing System to issue advisories and system updates.

The two FinCEN publications also provide great guidance on completing the required fields of the SAR and CTR.  On a side note, remember effective March 31, 2013, the filing period for CTRs is only 15 days.

Kris Welch, CRCM, CAMS is a long time banker and financial services consultant with over 25 years experience in regulatory compliance, risk assessments, financial institution branch management, and real estate appraisal. She has established, coordinated and maintained effective financial institution compliance and reporting programs.


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