Q: There are frequently asked questions regarding Filing SARs on Activity Outside the United States. The following discussion is contained in Section 6 of The SAR Activity Review – Trends, Tips & Issues (June 2001).
A: Consistent with the SAR regulations, it is expected that financial institutions will file SARs on activity deemed to be suspicious even when a portion of the activity occurs outside of the United States or the funds involved in the activity originated from outside the United States. Although foreign-located operations of U.S. organizations are not required to file SARs, an organization may wish, for example, to file a SAR with regard to suspicious activity that occurs outside the United States that is so egregious that it has the potential to cause harm to the entire organization. (It is, of course, expected that foreign-located operations of U.S. organizations that identify suspicious activity will report such activity consistent with local reporting requirements in the foreign jurisdiction where the operation is located.) (6/2001)
This FAQ was obtained from FinCEN’s website, in the section for Answers to Frequently Asked BSA Questions, which may be found here: