FinCEN Reports

Question 1

SAR

Answer 1

• applies to any activity an FI seems suspicious, threshold amount varies depending on type of FI
• for DIs, securities and futures broker dealers, and mutual funds: $5,000
• for all other FIs: $2,000

Question 2

What are the seven categories of suspicious activity on the SAR form?

Answer 2

Structuring
Fraud
ML
TF
Casinos
ID/documentation (if questionable)
Other

Must check all that apply

Question 3

For how long must a filer maintain a SAR and supporting documentation?

Answer 3

Five years

Question 4

How long does a filer have to report suspicious activity?

Answer 4

30 days after a subject has been identified; 60 days if a subject is not identified

Question 5

What is the most frequently filed BSA form?

Answer 5

CTR

Question 6

CTR Threshold and timeline

Answer 6

More than $10,000, in the course of a single business day

Must be filed within 15 calendar days of the transaction date

Question 7

8300 thresholds

Answer 7

Aggregates more than $10,000 in a 24 hour time window, or more than $10,000 if txns are connected within a 12-month timeframe

Question 8

Who must file 8300s?

Answer 8

Anyone acting in a trade or business who does not otherwise file CTRs

Question 9

Filing timeline for 8300

Answer 9

Must be done within 15 calendar days of transaction date

Question 10

Which activities trigger CMIR filing?

Answer 10

Individuals and businesses:

• mailing or shipping
• otherwise physically transporting

cash or equivalent in excess of $10,000 at one time either inbound or outbound of the US

Question 11

CMIR filing timeline

Answer 11

• at the time of the traveler’s physical cross-border movement
• within 15 days of receipt if mailed
• at the time of shipping funds out

Question 12

What is a DOEP?

Answer 12

A designation of exempt person form allows a heavy CTR filer to seek reprieve from needing to file with certain businesses that often deal in cash.

Question 13

How frequently must FIs review their eligibility for DOEPs?

Answer 13

Every calendar year

Question 14

What is an FBAR?

Answer 14

Must be filed by any US taxpayer with an overseas bank or similar financial account valued at more than $10k in a year.

Question 15

By when must an FBAR be filed?

Answer 15

By April 15 each calendar year

Question 16

By when must a new MSB file a new RMSB?

Answer 16

Within 180 days of business establishment.

Question 17

How are agents handled for RMSB purposes?

Answer 17

Only have to file if they themselves are carrying out separate MSB services. The MSB “principal” is instead Required to maintain a list of agents that must be ready for LEAd in request

Question 18

How often must an RMSB be updated?

Answer 18

Every two years.

Question 19

RMSB: what is the key information it provides?

Answer 19

• types of services offered (ie check cashing, remittance, FX, virtual assets)
• number and location of authorized agents
• primary transaction bank account information