Chapter 9: Financial Privacy
Suspicious Activity Reports and BSA Enforcement
Institutions must file a Suspicious Activity Report (SAR) with FinCEN for insider crimes regardless of amount, crimes of $5,000+ with a suspect, crimes of $25,000+ without a suspect, and suspected money-laundering currency transactions of $5,000+. BSA penalties include large fines and imprisonment, extending to crypto mixers.
| Situation | Threshold |
|---|---|
| Insider committing or aiding a crime | Any dollar amount |
| Possible crime with a substantial basis to identify a suspect | $5,000 or more |
| Possible crime with no substantial basis to identify a suspect | $25,000 or more |
| Suspected currency transactions involving money laundering or act violation | $5,000 or more (aggregated) |
Insider = no threshold
When an insider is suspected of committing or aiding a crime, a SAR is required regardless of dollar amount. The $5,000 and $25,000 thresholds turn on whether a suspect can be identified.
Key terms - quick answers
What is “Suspicious activity report (SAR)”?
A report financial institutions must file with FinCEN in defined situations to alert the government to potentially suspicious transactions.