SAR FAQs 2021 7 – Should financial institutions file additional SARs on the same suspicious activity to accommodate narratives that are longer than the SAR narrative character limits?

Compliance > BSA > FinCEN SAR FAQs
Q:   Should financial institutions file additional SARs on the same suspicious activity to accommodate narratives that are longer than the SAR narrative character limits??
 
A:   No. Filers must provide a clear, complete, and concise description of the suspicious activity that led to the decision to file the SAR. A financial institution that reaches the SAR narrative character limit should not file an additional SAR to continue a narrative in order to avoid duplicate filings on the same activity in the database. Instead, filers should focus the relevant information in the narrative as much as possible, and may include additional, relevant information as an attachment to the SAR, or note that it is available as supporting documentation.
 
To keep narratives within the character limit and enable efficient review of information (such as transaction records) that is displayed most clearly in tabular format, filers can include a single comma-separated values (CSV) file with no more than one megabyte of data as an attachment to a SAR. If a filer wishes to include information in a tabular format in a SAR, the CSV attachment should be used; filers should not include tabular information within the SAR narrative.
 
Filers must retain all supporting documentation or a business record equivalent for five years from the date of the report. All supporting documentation (such as copies of instruments; receipts; sale, transaction or clearing records; photographs; and surveillance audio or video recordings) must be made available to appropriate authorities upon request.
 
 
This Q&A was contained in the Interagency “Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations” dated January 19, 2021.  This issuance may be found here: 
 

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