FinCEN issued a reminder to financial institutions to ensure they adopt the new reports by April 1, 2013. The reports are available on FinCEN’s e-filing system. As stated by FinCEN:
“Specifically, this action mandates the electronic submission of Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs), Registration of Money Services Business (RMSBs), and Designation of Exempt Person Reports (DOEPs).”
Along with this change, I recommend that you take the time to update your policies and procedures to ensure you are citing the correct forms. Please keep in mind the new CTR is “FinCEN Form 112” and the new SAR is “FinCEN Form 111.”
Also, FinCEN made a point to remind credit unions that all mandated reports need to be filed electronically. After March 31, 2013, FinCEN stated that it may reject any paper filed reports and the financial institution may open themselves up to civil money penalties.
You have been warned!
Have a great week!