Together, these two new reports will replace FinCEN Form (CTR), FinCEN Form , FinCEN Form , and FinCEN Form ). E-Filing System. FinCEN is no longer accepting legacy reports. Bank Secrecy Act Forms and Filing Requirements. FinCEN SAR Form To file a FinCEN. The SAR MSB form, FinCEN , Suspicious Activity Report by Money Services Business, has been designed specifically for use by MSBs to report suspicious.

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Financial institutions may continue to use existing forms until July 1,at which point all CTR and SAR reports must be filed electronically. Though the newly released CTR and SAR forms contain new and expanded lists of data elements, FinCEN emphasized that the new forms do not change existing statutory and regulatory obligations.


FinCEN strongly recommends that institutions begin to file electronically before the July 1,mandate takes effect. Now that the system has been implemented, RMLOs can register rorm familiarize themselves with the new forms in advance of the August 13,compliance date. Starting April 1,a CTR must be filed within 15 days of the triggering transaction.

This marks a significant change from the current day compliance period. Click here to sign up for Ballard Spahr e-communications in a variety of practice areas.

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This alert is a periodic publication forj Ballard Spahr LLP and is intended to notify recipients of new developments in the law. It should not be construed as legal advice or legal opinion on any specific facts or circumstances.

FinCEN Form 109 Suspicious Activity Report Money Services Business

The contents are intended for general informational purposes only, and you are urged to consult your own attorney concerning your situation and specific legal questions you have.


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