Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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1/8/2006 Suspicious Activity Reports Revised For Joint Filings

Suspicious Activity Reports have been revised to provide for joint filings. The first section of the new depository institution SAR, the SAR-DI, FinCEN Form 111, asks the filer to check “if this report is being filed jointly with another financial institution.” In Part I, Subject Information, item 19 asks if the relationship is an insider relationship, and a Note under the item states: A joint SAR cannot be filed if item 19 is checked “yes.” In other words, joint filings are not to be made regarding insiders. In Part III, Reporting Financial Institution Information, item 33 contains space for the name of the financial institution, then asks: This is: a [ ] Filing institution or b [ ] Joint filer. A special note at the end of the form indicates that Parts III and IV must be completed for each institution. The instructions state that a copy of page 2, containing these Parts, is to be made and completed for each institution, including branch information if appropriate. Only one institution is to check “Filing institution,” while rest are to check [ ] Joint Filer. The Narrative in Part V is to indicate the number of filers. Changes that allow for joint filing were also made to the SAR-C (FinCEN Form 102, for casinos), the SAR-IC (FinCEN Form 108, for insurance companies), and the SAR-SF (FinCEN Form 101, for the securities and futures industries). These SARs are to be used after June 30, 2007. A new SAR-MSB (FinCEN Form 109, for money services businesses) will be available for use on March 31, 2007, but does not provide for joint filing. FinCEN indicates, however, that MSBs may be included as joint filers with other reporting financial institutions.

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