Suspicious Activity Report (SAR)
Confidential filing -- the unified FinCEN SAR (Form 111; the LEGACY broker-dealer form was SAR-SF, Form 101) -- that financial institutions submit to FinCEN when they detect transactions that appear designed to evade reporting requirements, have no apparent legitimate purpose, or involve funds derived from illegal activity. Judgment goes into DETECTION -- once the criteria are met, filing is mandatory. Broker-dealers MUST file when a suspicious transaction or pattern involves $5,000 or more (31 CFR 1023.320; filing below that is voluntary); banks must report insider abuse at any amount, $5,000+ with an identified suspect, and $25,000+ regardless of suspect (12 CFR 21.11). Due within 30 calendar days of initial detection, extendable to 60 when no suspect has been identified. The "no tipping off" rule (31 U.S.C. 5318(g)) makes it a federal crime to inform the client (or anyone outside the AML chain) that a SAR is being filed -- good-faith filings are protected from civil liability.
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Related terms
Anti-Money-Laundering (AML) · Currency Transaction Report (CTR) · Investment Policy Statement (IPS) · Know Your Client (KYC) · Onboarding Workflow · Politically Exposed Person (PEP)
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