Pub. 6 2018 Issue 2

www.uba.org 18 COMPLIANCE CORNER I n late January of 2018, FinCEN announced the update to the Sus- picious Activity Report (SAR) that will be available on June 22, 2018. The updated SAR form has been revised and includes half a dozen changes. These changes include: a new field that will alert FinCEN to the SAR being filed in response to specific geographic target- ing orders (GTO), advisories, or other activity, a new field for type of suspicious activity “Cyber Event”, a new field in the “Cyber Event” indicator field that allows the filer to report various events such as Command and control IP addresses, Ports, suspicious files names, and more. In conjunction with the new field, there were updates to existing fields such as: subtype selections associated with var- ious suspicious activity types, revisions to date and time stamp fields relating to activities being conducted on a schedule or random in nature, selections associat- ed with suspicious activity product types, and subtypes associated with Securities and Futures. In addition to the above not- ed revisions, batch filers will be required to submit SAR information in a XML file format rather than in fixed-length file delimitation, such as the current ASCII. First, let’s discuss the new field, located in Filing Institution note to FinCEN, which will alert FinCEN to the SAR being filed in response to specific GTO, advisories, or other activity. FinCEN announced in 2016 they were concerned that all-cash purchases may be conducted by individuals attempting to hide assets and their identity, by making those pur- FinCEN Announces Update to the Suspicious Activity Report (SAR) By Chance Williams, CRCM Compliance Specialist