Compliance Blog

Have you ever wondered what happened to the Financial Crimes Enforcement Network's (FinCEN) Suspicious Activity Report Statistics (SAR Stats)?  Well the data is still available; it's just gone totally interactive.

If you go to FinCEN's website www.fincen.gov, you can find a link for "SAR Statistics."

This link goes to the interactive report generator page:

  





The drop down boxes allow for filtering of the statistical data according to:  industry type; year & month; suspicious activity category/type; states/territories; county/metro & micro area; instrument type(s)/payment mechanism(s); product type; relationship; and regulator.  Each drop down allows for all, one, or multiple filter categories.  Once you have determined your filters, you can then generate a report and export it to a CSV file or to a PDF for further study.

FinCEN's FAQ/Glossary page cautions the statistics are:

"Statistical data for SARs are updated as information is processed and refreshed data is periodically made available for this tool. For this reason, there may be discrepancies between the statistical figures returned from queries performed at different times. In addition, slight differences in query criteria may return different statistical results. Also note that the statistics generated by this tool do not include SAR fields that contain unknown or blank data. To the extent statistics including blank or unknown data are tabulated outside of this tool for other purposes, there may be discrepancies between statistics generated by this tool and those generated through other means. FinCEN makes no claims, promises or guarantees about the accuracy or completeness of the statistical figures provided from this tool and expressly disclaims liability for errors, omissions, or discrepancies in the statistical figures."

Still, the generated reports can indicate trends in your area, state or region of your part of the country and can be a useful additional resource for BSA compliance personnel.  The website indicates the data has been updated as of November 30, 2017.

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Sessions Releases Marijuana Memo.  Attorney General Jeff Sessions released a memorandum on federal marijuana enforcement policy.  Basically the Department of Justice has rescinded the Obama administration policy of non-interference with marijuana-friendly state laws.  Look for more on this in a blog next week.

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BSAAG.  FinCEN is asking for nominees for membership on the Bank Secrecy Act Advisory Group (BSSAG).  New members will be selected for three-year membership terms.  If you would like more information or are interested in having NAFCU submit you as a candidate, please email Senior Regulatory Affairs Counsel Michael Emancipator at memancipator@nafcu.org by January 15 as potential nominees must be submitted to FinCEN by January 26, 2018.