Bank Secrecy Act & SAR Filing Flashcards

Under the Bank Secrecy Act, what is the minimum threshold for filing a Currency Transaction Report (CTR)?

Answer: $10,000

Financial institutions must file a CTR for cash transactions exceeding $10,000 in a single business day.

A bank customer conducts five separate $3,000 cash deposits on the same day to avoid CTR reporting. This activity is known as:

Answer: Structuring (smurfing)

Structuring, or smurfing, involves breaking up transactions to stay below reporting thresholds, which is itself a federal crime under the BSA.

Which federal agency serves as the administrator of the Bank Secrecy Act and receives BSA filings?

Answer: FinCEN

The Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury, administers the BSA and collects BSA reports.

A SAR must generally be filed within how many calendar days after a suspicious activity is initially detected?

Answer: 30 days

Financial institutions must file a SAR within 30 calendar days of initial detection of suspicious activity, with a 60-day extension if no suspect is identified.

Which of the following is NOT a covered financial institution required to file SARs under BSA regulations?

Answer: Retail clothing stores

Retail businesses like clothing stores are not covered financial institutions under the BSA and have no SAR filing obligation.

The 'tipping off' prohibition in the BSA means that a financial institution:

Answer: Cannot disclose to the subject that a SAR has been filed

The BSA explicitly prohibits financial institutions from disclosing to the subject of a SAR that a report has been filed, protecting the integrity of investigations.

A SAR filed by a bank employee in good faith is protected from civil liability under which BSA provision?

Answer: Safe harbor provision

The BSA's safe harbor provision protects financial institutions and their employees from civil liability when filing SARs in good faith.