Suspicious Activity Report

FR2230_20160225_i

Suspicious Activity Report

OMB: 7100-0212

⚠️ Notice: This form may be outdated. More recent filings and information on OMB 7100-0212 can be found here:

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Financial Crimes Enforcement Network

FinCEN Suspicious Activity Report
(FinCEN SAR) Electronic Filing Requirements
Release Date March 2015 – Version 1.4

DEPARTMENT OF THE TREASURY

Financial Crimes Enforcement Network (FinCEN)

Financial Crimes Enforcement Network

Table of Contents
Revision History

Purpose

Electronic Filing

File Organization

Record Layouts

Transmitter (1A) Record – Required

Filing Institution Information (2A) Record – Required

Financial Institution Where Activity Occurred (2B) Record – Required

Branch or Office Institution Where Activity Occurred (2C) Record

Suspicious Activity Information (3A) Record – Required

Commodity Type (3B) Record

Product/Instrument Description (3C) Record

Market Where Traded (3D) Record

IP Address (3E) Record

CUSIP Number (3F) Record

Subject (4A) Record – Required

Subject Address (4B) Record

Subject Identification (4C) Record

Subject Alternative Name (4D) Record

Subject Telephone Number (4E) Record

Subject E-mail Address (4F) Record

Subject Website (URL) Address (4G) Record

Subject Relationship to Institution (4H) Record

Affected TIN & Account Number (4I) Record

Narrative Description (5A) Record – Required

Suspicious Activity Information Summary (9A) Record – Required

Filing Institution Summary (9B) Record – Required

File Summary (9Z) Record – Required

Acknowledgement Record Formats

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Acknowledgement Transmitter (1A) Record

Acknowledgement Filing Institution Information (2A) Record

Acknowledgement Financial Institution Where Activity Occurred (2B) Record

Acknowledgement Branch or Office Where Activity Occurred (2C) Record

Acknowledgement Suspicious Activity (3A) Record

Acknowledgement Commodity Type (3B) Record

Acknowledgement Product/Instrument Description (3C) Record

Acknowledgement Market Where Traded (3D) Record

Acknowledgement IP Address (3E) Record

Acknowledgement CUSIP Number (3F) Record

Acknowledgement Subject (4A) Record

Acknowledgement Address (4B) Record

Acknowledgement Identification (4C) Record

Acknowledgement Alternative Name (4D) Record

Acknowledgement Telephone (4E) Record

Acknowledgement E-mail Address (4F) Record

Acknowledgement Website (URL) Address (4G) Record

Acknowledgement Relationship to Institution (4H) Record

Acknowledgement Affected TIN & Account Number (4I) Record

Acknowledgement Trailer for Transmitter (9Z) Record

Attachment A – Error Code List

Attachment B – Error Correction Instructions

Attachment C – Electronic Filing Instructions

Attachment D – Batch Attachments

114

Attachment E- Batch File Sample Layouts

116

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Revision History
Version
Number

Date

Reason for Change

1.0

09/22/11

Removes step to rename BSA SAR batch attachment zip file to *.bsazip
prior to submission (Attachment D – Batch Attachments).

1.1

03/22/12

Updates electronic specification document title from “BSA Electronic
Requirements for Bank Secrecy Act Suspicious Activity Report (BSA
SAR)” to “FinCEN Suspicious Activity Report (FinCEN SAR) Electronic
Filing Requirements” and replaces “BSA SAR” with “FinCEN SAR”
through the document.
Updates Part IV TIN (Item 80, 2A record, pos. 155-179) Description and
Remarks to replace “less than” with “not equal to” in the following
statement: “A TIN entry is also invalid if it is not equal to 9 numbers and
Part IV TIN Type is “A” or “B.””
Updates Part IV Financial Institution Identification Type (Item 84)
Description and Remarks to include the full description for each
identification type (e.g. “CRD number” changed to “Central Registration
Depository (CRD) number”).
Updates Part III Financial Institution Identification Type (Item 51)
Description and Remarks to include the full description for each
identification type (e.g. “CRD number” changed to “Central Registration
Depository (CRD) number”).
Updates Part III TIN (Item 55, 2B record, pos. 503-527) Description and
Remarks to replace “less than” with “not equal to” in the following
statement: “A TIN entry is also invalid if it is not equal to 9 numbers and
Part III TIN Type is “A” or “B.””
Updates Part III Branch or Office Country (Item 70, 2C record, pos. 176177) Description and Remarks to make this field REQUIRED when a
branch or office 2C record is recorded.
Deletes “Attachment C – Field Editing Instructions” after incorporating the
data in “Attachment D – Electronic Filing Instructions” as General
Instructions “11. Prohibited Words and Phrases” and “12. Name Editing
Instructions.” Changed “Attachment D” to “Attachment C” and
“Attachment E” to “Attachment D” throughout the document as a result.
Removes the option to enter an internal file number if correcting/
amending a prior report; updates Field Name/Description and Remarks
(3A record, pos. 12-25), as well as Attachment C – Electronic Filing
Instructions, to reflect this change to Item 1.
Updates Field Name for Item 96 (3A record, pos. 1113-1122) and Item 97
(3A record, pos. 1123-1138 & 1139-1144), as well as Attachment C –
Electronic Filing Instructions, to replace the word “Designated” with
“Filing Institution,” and updates the Description and Remarks
accordingly.

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Reason for Change
Updates TIN (Item 13, 3A record, pos. 304-328) Description and Remarks
to replace “less than” with “not equal to” in the following statement: “A
TIN entry is also invalid if it is not equal to 9 numbers and TIN Type is
“A” or “B.””
Updates Part I State Unknown (Item 10, 4B record, pos. 163) Description
and Remarks to include the following: “If the subject's state is unknown
and Part I Country is “US,” “CA,” “MX,” or unknown, enter "X”.
Otherwise space-fill.”
Added the following clarifying language to the Error Codes Description
and Remarks (Acknowledgement Transmitter (1A) Record, pos. 30-119):
“…Error codes associated with this record begin with a “T,” are 3
alphanumeric characters in length, and are left-justified…”
Removes error codes S253 and S254 from Attachment A – Error Code List.
Updates error code S258 Error Description in Attachment A – Error Code
List for clarification by removing validation that branch/office street
address and branch/office country cannot both be blank and replaced with
the following description: “Branch/office country is blank and Part III No
Branch Activity (Item 65) is blank.”
Updates error code S205, S238, and S416 in Attachment A – Error Code
List to include the following explanation as to why the TIN entry is
invalid: “…TIN is an invalid number string such as all zeros, all nines,
123456789, or a U.S. TIN and not nine digits.
Updates General Instructions 6 (Supporting Documentation) of
Attachment C – Electronic Filing Instructions, as well as Attachment D –
Batch Attachments, to clarify that only comma separated (.CSV) files are
the only form of acceptable attachments for FinCEN SAR reports.
Updates Date of Birth (Item 16) instructions, located in Attachment C –
Electronic Filing Instructions, to include language that explains how to
enter dates on a discrete file vs. a batch file (i.e. MM/DD/CCYY for discrete
files; MMDDCCYY for batch files).
Updates Relationship of subject to an institution (Item 21) instructions,
located in Attachment C – Electronic Filing Instructions, to include the
following sentence at the end of the paragraph: “If more than one of 21h
“Director,” 21i “Employee,” 21k “Officer,” or 21l “Owner or Controlling
Shareholder” is selected and/or the status or action date is different for
each, an Item 21 for each must be completed.”
Updates “Item *27 Date or date range of suspicious activity for this report”
instructions, located in Attachment C – Electronic Filing Instructions, to
include the following sentence at the end of the paragraph: “Use the
format MM/DD/CCYY for dates in a discrete FinCEN SAR and the format
MMDDCCYY for dates in a batch-filed FinCEN SAR.”
Updates “Item 53 Legal name of financial institution” instructions, located
in Attachment C – Electronic Filing Instructions, to include the following
statement: “…Enter the full name of the filer if the filer is an individual,
such as a sole proprietorship, acting as a financial institution. If an

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individual’s name is recorded, enter the name in (first name) (middle
name) (last name) or equivalent format, e.g. John Jacob Doe or Richard R.
Roe II, etc…”
Updates Item 70 title, located in Attachment C – Electronic Filing
Instructions, to include the following: “(* if 65a is NOT selected…”
Updates “Item *79 Filer name” instructions, located in Attachment C –
Electronic Filing Instructions, to include the following statement: “…Enter
the full name of the filer if the filer is an individual, such as a sole
proprietorship, acting as a financial institution. If an individual’s name is
recorded, enter the name in (first name) (middle name) (last name) or
equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc.”
Updates error code F88 in Attachment A – Error Code List to remove the
reference to “code” at the end of the error description. The updated
description for F88 is now “The Transmitter Control Code (TCC) specified
in the file is not a valid production TCC.”
Removes reference to BSA E-Filing website for ISO information from the
“Address” instructions located in Attachment C – Electronic Filing
Instructions, as no such information is posted to the BSA E-Filing site at
this time.
Removes “alphanumeric” as an invalid form of entry for the Transmitter
TIN in the 1A record, position 483-507.
Replaced “Document Control Number” field within each
acknowledgement record to now read “BSA Identifier.”
Updates the location of the approved list of NAICS codes (Item 7) to
http://bsaefiling.fincen.treas.gov/main.html. The change can be seen in the
4A record, position 298-303, as well as Attachment C – Electronic Filing
Instructions.
Updates field positions associated with the Filler (was 198-1210; now 1981190) and User Field (was 1211-1220; now 1191-1200) in the 2C Record.
Updated the Description and Remarks associated with the Subject ID
Issuing State (Item 15) in the 4C record (position 33-35) to the following:
“Enter the appropriate two or three character code when the identification
was issued by a known state, province, or territory of the United States,
Canada, or Mexico. See General Instruction 7 in Attachment C for
information about the codes to be entered. Otherwise space-fill this field.”
Adds the following lead sentence to the General Instructions “12. Name
Editing Instructions” of Attachment C – Electronic Filing Instructions:
“When recording the name of an individual, a filer should enter the last
name/family name or equivalent in a last name field, the first name or
equivalent in the first name field, middle name or equivalent in the middle
name field, and name suffix (such as JR, SR, III, etc) in the suffix field
whenever these fields are provided.”
Updates the following FinCEN SAR Filing Instructions, located in
Attachment C – Electronic Filing Instructions:

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Reason for Change
 In “1. Who Must File” added “163.180,” to the 12 C.F.R. citations in
the first sentence. In the second sentence changed Banks (31 CFR
§1020.320);” to “Banks (31 CFR §1020.320) including Bank and
Financial Holding Companies (12 CFR § 225.4);”.
 In “4. Additional Filing Instructions for Banks” added “163.180,” to
the 12 C.F.R. citations.
Updates the following General Instructions, located in the FinCEN SAR
Electronic Filing Instructions section of Attachment C – Electronic Filing
Instructions:
 In “2. Recording Information” added “even when the required data
are unknown” to the end of the first sentence. Deleted “or not
applicable” from the end of the second sentence. Inserted the
following sentences between the second and third sentences: “Items
that do not begin with an asterisk must be completed if the data are
known and will be left blank if the data are unknown. If an item’s
instructions differ from this general instruction, the item instructions
must be followed.” Changed “data is unknown” to “data are
unknown” in the second to last sentence.
 In “3. Corrected/Amended Reports” inserted “or prior SAR versions”
after “FinCEN SAR” in the first and second sentences. Added the
following sentence to the end of the instruction: “BSAIDs, which
replaced DCNs, are provided in acknowledgement records sent to
member financial institutions by the BSA E-Filing System.”
 In “6. Supporting Documentation” added “(31 CFR § 1010.430)” to
the end of the sixth sentence that references retention of supporting
documents for 5 years.
Updates the following Item Instructions, located in the FinCEN SAR
Electronic Filing Instructions section of Attachment C – Electronic Filing
Instructions:
 In “16. Date of birth” changed all references to “15” to “16.”
 In “24. Financial institution TIN…” added “If the TIN is unknown
leave the TIN field blank” following the sixth sentence. Changed the
start of sentence “When there are multiple Part III institutions
recorded in the FinCEN SAR and the TIN of the financial institution
associated with account numbers is unknown,” to read “If the TIN of
a financial institution associated with an account number entered in
24d is unknown,”.
 In “28 Cumulative amount…” added “, including the current FinCEN
SAR.” to the end of the second sentence.
 In the introductory paragraph for Part III, changed the fourth
sentence to read: “If a financial institution recorded in Part III has
branches involved in the suspicious activity, record the branch
information in Items 64 through 70. Information on up to 99
branches can be recorded in a single SAR.” Deleted the sentence “Do
not provide separate Part III records on branches.”
 In “52. Financial institution’s role…” changed the instruction to read
as follows: “Check box 52a “Selling location” if the customer
purchased at the Part III financial institution the products or

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




1.2

09/19/12

instruments recorded in Items 39 or 40. Check box 52b “Paying
location” if the customer received payment from the Part III financial
institution for the products or instruments recorded in Items 39 or
40. Check box 52c “Both” if the Part III financial institution was both
a paying and selling location for the products or instruments
recorded in Items 39 or 40.”
In “62. Internal control/file number” inserted “, if applicable,” after
“file number” in the first sentence.
In“64. Branch’s role in transaction” changed the instructions to read:
“Check box 64a “Selling location” if the customer purchased at the
Part III financial institution branch the products or instruments
recorded in Items 39 or 40. Check box 64b “Paying location” if the
customer received payment from the Part III financial institution
branch for the products or instruments recorded in Items 39 or
40. Check box 64c “Both” if the Part III financial institution branch
was both a paying and selling location for the products or
instruments recorded in Items 39 or 40. This item must be blank if no
branch is involved in the suspicious activity. If multiple branches are
involved in the suspicious activity, a separate Item 64 must be
prepared for each branch.”
In “92. LE contact agency” added the following note to the
instructions. “NOTE: If more than one LE agency has been contacted
about the suspicious activity, record the information on one agency in
Items 92-95 and the information on additional agencies in Part V.”
In Part V changed the third bullet to read as follows. “If any item in
the report was insufficient for recording all item data held by the
filer, or if an item’s instructions require entry of additional data or
explanation in the narrative, record the additional data referenced by
item number in the narrative.
In Part V deleted the bullet that begins “Recommend any further
investigation….”

General Updates
 FinCEN SAR “report”
Replaces the reference to the FinCEN SAR as a “form” with “report”
throughout the document.
 Acknowledgement File Format
Updates the acknowledgement file format to include User Field
values from incoming records.
Updates to File Organization:
 Financial Institution Where Activity Occurred (2B) Record
Replaces the statement "…for each financial institution reporting
under the Filing Institution (2A) Record" with "under the Filing
Institution Information (2A) Record for each financial institution
where the suspicious activity occurred.” Also removes the reference
to "suspicious activity report" from the end of the second sentence
and replaces it with "FinCEN SAR."
 Subject (4A) Record

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Removes the statement “or joint filing.”
Updates to Record Layouts:
 Transmitter ZIP/Postal Code (as well as Items 11/60/69/88)
Updates the Description and Remarks to include “or four nines” in
the following sentence: “A nine-digit entry cannot end with four
zeros or four nines …”
 Part IV Filer Name (Item 79)
Updates the Description and Remarks to replace the statement “Enter
the complete name of the filing institution” with “Enter the legal
name of the filing institution as recorded on articles of incorporation
or other documents establishing the institution.”
 Part IV Type of Securities and Futures Institution – Other (Item
50/83)
Updates the Description and Remarks to replace “is” with “contains”
in the following sentence: “If the "Securities and Futures Institution
Type” contains “Z,” enter a brief…”
 Part III TIN Type (Item 56)
Updates the Description and Remarks to replace the statement
“…follow form instructions for determining the TIN type code to
enter” with “…follow the Item 56 instructions in Attachment C to
determine the TIN Type code to enter.”
 Part III Loss to Financial Institution (Item 63)
Updates the Description and Remarks to include the following: “See
the Item 63 instructions in Attachment C for further information on
entering amounts in this item.” Attachment C Item 63 instructions
now includes the statement “The amount entered in this field cannot
be zero and cannot be greater than the amount in Item 26 “Amount
involved in this report.””
 Prior Report Document Control Number/ BSA Identifier (Item 1)
Updates the Description and Remarks to include the following: “If
the DCN or BSA ID is unknown, enter zeros in place of the unknown
number.”
 Amount Involved In This Report (Item 26)
Updates the Description and Remarks to replace the statement “Zero
is not an amount” with “Zero is not an amount, so the entry “0” for
the amount involved is NOT permitted in this item.”
 Cumulative Amount (Item 28)
Updates the Description and Remarks to include the following: “See
the Item 28 instructions in Attachment C for additional information
on entering amounts in this field.”
 Structuring (Item 29) (as well as Items: 30-39)
Updates the Description and Remarks to replace the instruction to
“Left justify and zero-fill” with “Left justify and space-fill.”
 Instrument Type(s)/Payment Mechanism(s) Involved (Item 40)
Updates the Description and Remarks to include the following: “Left
justify and space-fill the entry. Do not include spaces between
multiple entries.”
 CUSIP Number (Item 45)
Updates the Description and Remarks to the following: “Enter the

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CUSIP Number of any securities product involved in the suspicious
activity. Left justify and space-fill this entry.”
 First Name (Item 4)
Updates the Description and Remarks to replace the statement
“Space-fill if “First Name Unknown” contains “X”” with “Space-fill if
“First Name Unknown” contains “X,” “If Entity” contains “A,” or “If
All Critical* Subject Information Is Unavailable” contains “B.””
 NAICS Code (Item 7)
Updates the Description and Remarks to replace the statement
“Access the NAICS Code like from…” with “Use only the codes from
the NAICS Code list found on…” Also adds the following statement:
“Use of codes not found on that list is prohibited.”
 Relationship of the Subject to an Institution (Item 21)
Updates the Field Name to replace the name “Relationship of the
Subject to an Institution” with “Institution TIN” for field positions 832 of the Subject Relationship to Institution (4H) Record
Updates to Attachment B – Error Correction Instructions:
 Error Categories
Replaces the statement “fatal errors that result” with “format errors
that may result”.
 Correction Procedures
Updates the third bullet to include “file” in the following statement:
“Enter the prior report’s BSA Identifier from the FinCEN SAR
acknowledgement file at Field Position 12-25 “Prior Report
Document Control/File Number” in the Suspicious Activity
Information (3A) Record for each corrected FinCEN SAR.”
Updates to Attachment C – Electronic Filing Instructions:
 FinCEN SAR Filing Instructions (1. Who must file)
Adds Residential Mortgage Lenders and Originators to the list of
financial institutions required to file a FinCEN SAR. As a result,
includes “and Residential Mortgage Lenders and Originators (31 CFR
§ 1029.320)” at the end of the instructions.
 FinCEN SAR Filing Instructions (7. Additional Reporting)
Adds the following statement to the end of the instructions:
“Residential Mortgage Lenders and Originators are required to file
Form 8300, Report of Cash Payments Over $10,000 Received in a
Trade or Business, instead of a CTR.”
 General Instructions (3. Corrected/Amended Reports)
Updates “3. Corrected/Amended Reports” to include the statement
“If the prior report’s DCN or BSA ID is unknown, field 1e should be
zero-filled.”
 General Instructions (12. Name Editing Instructions)
Updates “12. Name Editing Instructions” to match the instructions in
the FinCEN CTR and DOEP.
 Item Instructions (Item *1 Type of Filing)
Updates “Item 1 Type of Filing” to include the statement “If the DCN
or BSA ID is unknown, enter zeros in place of the unknown number.”
 Item Instructions (Item 4. First name)

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Updates “Item *4 First name” to include “2a or” in the following
statement: “Leave Item 4 and box 4 “Unknown” blank if box 2a or 2b
is checked.”
 Item Instructions (Items: 19. E-mail address, 19a. Website (URL)
address)
Removes the statements “Multiple Item 19 fields may be completed if
multiple e-mail address for the subject are known” and “Multiple
Item 19a fields may be completed if multiple website address for the
subject are known” from the item instructions for these items. Those
options were stated in the instructions twice.
 Item Instructions (Item 47. Type of financial institution)
Updates “Item 47 Type of financial institution” to replace the
following with what is listed now: “Record the type of financial
institution entered in Part III by selecting the appropriate option in
Item 47. If none of options 47a through 47e are appropriate, select
option 47z "Other" and enter a brief description of the type of
financial institution in the associated text field. If necessary, include a
more detailed description in Part V. If option 47a Casino/Card Club is
selected, then Item 49 for type of gaming institution must be
completed. If option 47e Securities/Futures is selected, then Item 50
for type of securities and futures institution must be completed.” See
updated instructions in Attachment C.
 Item Instructions (Item 82. Type of financial institution)
Updates “Item 82 Type of financial institution” to include the
following note: “NOTE: If the financial institution is a non-bank
residential mortgage lender or originator, select “Other” and enter
“NON-BANK RESEDENTIAL MORTGAGE” in the associated text
field. If the financial institution is a dealer in precious metals, stones,
or jewels, select option “Other” and enter “DEALER IN PRECIOUS
METALS STONES JEWELS” in the associated text field.”
Updates to Attachment D – Batch Attachments:
 Secure Data Transfer Mode Users
Updates the instructions to include naming convention and
attachment file structure information related to SDTM/System to
System filers.

1.3

09/27/14

Updates to Record Layouts
 Filing Institution Information (2A) Record:
o Added “Federal Housing Finance Agency (FHFA)” to Part IV
Primary Federal Regulator (Item 78).
o Added “Loan or Finance Company” and “Housing GSE” to Part
IV Type of Financial Institution (Item 82).
o Added “National Association of Insurance Commissioners
(NAIC Code)” and “Mortgage (NMLS ID)” to Part IV Financial
Institution Identification Type (Item 84).
 Financial Institution Where Activity Occurred (2B) Record:
o Added “Loan or Finance Company” and “Housing GSE” to Part

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III Type of Financial Institution (Item 47).
o Added “Federal Housing Finance Agency (FHFA)” to Part III
Primary Federal Regulator (Item 48).
o Added “National Association of Insurance Commissioners
(NAIC Code)” and “Mortgage (NMLS ID)” to Part III Financial
Institution Identification Type (Item 51).
Updates to Attachment C – Electronic Filing Instructions
 General Instructions (7. Addresses):
o Removed “Note: The ISO 3166-1 country list includes entries for
all U.S. territories. Do not use these U.S. territory entries, which
match the U.S. Postal Service abbreviations required in state
fields, in any country field.” Added “Note: The ISO 3166-1
country list contains entries for all U.S. territories, including the
United States Minor Outlying Islands. Do not use these U.S.
territory entries, which may match the U.S. Postal Service
abbreviations required in state fields, in any country field.”
 Item Instructions:
o Updated the following items to correspond with the field entry
additions in the 2A and 2B records mentioned above: 47, 48, 51,
78, 82, and 84.
Updates to Attachment D – Batch Attachments
 Added the following instructions:
“NOTE: Please be advised that when entering data into an Excel
spreadsheet prior to saving it as a comma separated (.CSV) file, the
default behavior for numeric data entered into cells is to convert
numeric values over 11 characters into scientific notation. For
example, the value of 123456789123 is converted to 1.23457E+11 after
entry. When the Excel spreadsheet is saved to a comma separated
(.CSV) fill, this visible format is retained and when opened the entire
original number is not displayed, 123456789123, but rather
1.23457E+11.To avoid this behavior, please ensure that your
workbook cells are formatted as text prior to entering data in the cell.
This can be accomplished by selecting the column, right clicking the
mouse and selecting Format Cells, and then selecting Text under
Category, and then OK. This must be done before entering the data,
not after.”

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1.4

03/15/2015

Updates to Attachment C – Electronic Filing Instructions
 General Instructions (7. Addresses):
Removed “Note: The ISO 3166-1 country list contains entries for all U.S.
territories, including the United States Minor Outlying Islands. Do not
use these U.S. territory entries, which may match the U.S. Postal Service
abbreviations required in state fields, in any country field.”
This change was made as the discrete (online) reports were updated to
include the following entries in Country fields:
American Samoa, (AS)
Guam, (GU)
Marshall Islands (the), (MH)
Micronesia (the Federated States of), (FM)
Northern Mariana Islands (the), (MP)
Palau, (PW)
Puerto Rico, (PR)
Virgin Islands (U.S.), (VI)
These values can now be used in Country fields to adhere to the ISO
3166-1 standard.
Updates to Item 9 in General Instructions
Changed last sentence in instruction
From:


Such numbers include alien registration, CRD, CUSIP®, driver’s
license, state identification, EIN, IARD, ITIN, passport, RSSD,
SEC ID, and SSN.

To:


Such numbers include account numbers, alien registration
numbers, CRD, CUSIP®, driver’s license numbers, state
identifications, EINs, IARDs ITINs, passport numbers, RSSDs,
SEC IDs, and SSNs.

Updates to Item 24 in General Instructions
Added the following sentence:


Enter account numbers without formatting or special characters
such as spaces, hyphens, or periods.

Addition of a new Attachment E – Batch File Layout Examples


This new section provides additional instruction on the layout of
the batch files along with examples.

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Purpose
The purpose of this document is to provide the requirements and conditions for electronically
filing the FinCEN Suspicious Activity Report (FinCEN SAR). Electronic filing of this report will
be through the BSA E‐Filing System operated by the Financial Crimes Enforcement Network
(FinCEN). For more information on the BSA E‐Filing System and to register, please go to
http://bsaefiling.fincen.treas.gov. This document should be used in conjunction with the
“General Specifications for Electronic Filing of Bank Secrecy Act (BSA) Reports” (General
Specifications) available at http://www.fincen.gov/forms/files/e-filing_GENspecs.pdf. It is
recommended that you refer to the General Specifications first, and then the specific
information contained in this document. If the General Specifications conflict with any specific
requirement found in this document, the specific requirement should be followed. Additional
instructions concerning the data to be entered in the electronic file are found in Attachment C –
Electronic Filing Instructions.

Electronic Filing
The BSA E‐Filing System Batch File Testing Procedures are detailed in a separate document that
can be accessed on the BSA E‐Filing System web site at http://bsaefiling.fincen.treas.gov under
Quick Links. For purposes of this document, the filer is the organization responsible for filing
the FinCEN SAR and the transmitter is the organization responsible for preparing the electronic
files. The filer and transmitter may be the same or different organizations. Filers are required to
retain a copy of the FinCEN SAR data and all original supporting documentation or business
record equivalent for five years from the date of the suspicious activity report. All supporting
documentation must be made available to appropriate authorities upon request.

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File Organization
The following data controls must be followed or the FinCEN SAR electronic file will be rejected.
The data records must be in the following sequence:
Transmitter (1A) Record – Required
There can only be one of this record type and it must be the first record on the file.
Filing Institution Information (2A) Record – Required
There must be one of this record type for each Filing Institution on the file. This record type
immediately precedes all records related to the filing institution identified in Part IV. The 2A
record may be associated with multiple FinCEN SARs.
Financial Institution Where Activity Occurred (2B) Record – Required
There must be at least one of this record type under the Filing Institution Information (2A)
Record for each financial institution where the suspicious activity occurred. This record type
precedes all records related to the financial institution(s) identified in Part III for a particular
FinCEN SAR. Filers are permitted to associate up to 99 2B records for a single FinCEN SAR.
Multiple 2B records for a single FinCEN SAR must occur prior to the associated Suspicious
Activity Information (3A) Record.
Branch or Office Institution Where Activity Occurred (2C) Record
There can be one or more of this record type when one or more branches or offices are involved
in the suspicious activity. Filers are permitted to associate up to 99 2C records for each Financial
Institution Where Activity Occurred (2B) Record on the file. All 2C records must be grouped
under the associated 2B record.
Suspicious Activity Information (3A) Record – Required
There can only be one of this record type for each suspicious activity or joint filing being
reported for the financial institution(s) identified in the associated 2B record(s). Filers are NOT
permitted to associate multiple Suspicious Activity Information (3A) Records under one or
more shared 2B/2C records.
Commodity Type (3B) Record
There can be more than one of this record type depending on the number of different
commodity types associated with a suspicious activity reported on the file. Filers are permitted
to associate up to 99 3B records for each Suspicious Activity Information (3A) Record on the file.

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Product/Instrument Description (3C) Record
There can be more than one of this record type depending on the number of different
product/instrument descriptions associated with a suspicious activity reported on the file. Filers
are permitted to associate up to 99 3C records for each Suspicious Activity Information (3A)
Record on the file.
Market Where Traded (3D) Record
There can be more than one of this record type depending on the number of different markets
where traded associated with a suspicious activity reported on the file. Filers are permitted to
associate up to 99 3D records for each Suspicious Activity Information (3A) Record on the file.
IP Address (3E) Record
There can be more than one of this record type depending on the number of different IP
addresses associated with a suspicious activity reported on the file. Filers are permitted to
associate up to 99 3E records for each Suspicious Activity Information (3A) Record on the file.
CUSIP Number (3F) Record
There can be more than one of this record type depending on the number of different CUSIP
numbers associated with a suspicious activity reported on the file. Filers are permitted to
associate up to 99 3F records for each Suspicious Activity Information (3A) Record on the file.
Subject (4A) Record – Required
There must be one of this record type for each subject involved in the suspicious activity. Filers
are permitted to associate up to 999 4A records for each Suspicious Activity Information (3A)
Record on the file.
Subject Address (4B) Record
There can be more than one of this record type depending on the number of different addresses
associated with a subject reported on the file. Filers are permitted to associate up to 99 4B
records for each Subject (4A) Record on the file. All 4B records for a particular subject must be
grouped under the associated Subject (4A) Record.
Subject Identification (4C) Record
There can be more than one of this record type depending on the number of different forms of
identification associated with a subject reported on the file. Filers are permitted to associate up
to 99 4C records for each Subject (4A) Record on the file. All 4C records for a particular subject
must be grouped under the associated Subject (4A) Record.

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Subject Alternative Name (4D) Record
There can be more than one of this record type depending on the number of different
alternative names associated with a subject reported on the file. Filers are permitted to associate
up to 99 4D records for each Subject (4A) Record on the file. All 4D records for a particular
subject must be grouped under the associated Subject (4A) Record.
Subject Telephone Number (4E) Record
There can be more than one of this record type depending on the number of different telephone
numbers associated with a subject reported on the file. Filers are permitted to associate up to 99
4E records for each Subject (4A) Record on the file. All 4E records for a particular subject must
be grouped under the associated Subject (4A) Record.
Subject E-mail Address (4F) Record
There can be more than one of this record type depending on the number of different e-mail
addresses associated with a subject reported on the file. Filers are permitted to associate up to
99 4F records for each Subject (4A) Record on the file. All 4F records for a particular subject
must be grouped under the associated Subject (4A) Record.
Subject Website (URL) Address (4G) Record
There can be more than one of this record type depending on the number of different website
(URL) addresses associated with a subject reported on the file. Filers are permitted to associate
up to 99 4G records for each Subject (4A) Record on the file. All 4G records for a particular
subject must be grouped under the associated Subject (4A) Record.
Subject Relationship to Institution (4H) Record
There can be more than one of this record type depending on the number of different institution
relationships associated with a subject reported on the file. Filers are permitted to associate up
to 99 4H records for each Subject (4A) Record on the file. All 4H records for a particular subject
must be grouped under the associated Subject (4A) Record.
Affected TIN & Account Number (4I) Record
There can be more than one of this record type depending on the number of different affected
institution TINs and/or account numbers associated with a subject reported on the file. Filers
are permitted to associate up to 99 4I records for each Subject (4A) Record on the file. All 4I
records for a particular subject must be grouped under the associated Subject (4A) Record.

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Narrative Description (5A) Record – Required
There can be more than one of this record type depending on the length of the narrative
description given for the suspicious activity on the file. A maximum of 20 5A records may be
associated with a Suspicious Activity Information (3A) Record.
Suspicious Activity Information Summary (9A) Record – Required
There must be one 9A record for each Suspicious Activity Information (3A) Record reported
and it must follow the last Narrative Description (5A) Record for the associated FinCEN SAR.
Filing Institution Summary (9B) Record – Required
There must be one of this record type for each Filing Institution Information (2A) Record on the
file and it must be the last record associated with the filing institution.
File Summary (9Z) Record – Required
There must be one of this record type on the file and it must be the last record.

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Record Layouts
Transmitter (1A) Record – Required
The first record on each file must be the Transmitter (1A) Record, which will contain
information identifying the batch file transmitter (person or organization handling the data
accumulation and formatting). There will be only one transmitter record on each electronic file.
All data elements for this record are required.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

3-152

Transmitter Name

150

REQUIRED. Enter the full name of the individual or
organization that is transmitting the reports in this file. Left
justify and space-fill the entry.

153-252

Transmitter Address

100

REQUIRED. Enter the street address of the transmitter. Left
justify and space-fill the entry.

253-302

Transmitter City

REQUIRED. Enter the city of the transmitter. Left justify and
space-fill the entry.

303-305

Transmitter State

REQUIRED. Enter the state code of the transmitter if the
Transmitter Country code is CA, MX, or US. See General
Instruction 7 in Attachment C for information about the codes to
be entered. Space-fill if no entry.

306-314

Transmitter
ZIP/Postal Code

REQUIRED. Enter the ZIP Code or foreign postal code for the
transmitter. Do not include punctuation or formatting such as
hyphens, periods, and spaces within the entry. An entry must
be five or nine digits if the "Transmitter Country" is "US." A
nine-digit entry cannot end with four zeros or four nines if
"Transmitter Country" is "US." Left justify and space-fill this
entry if less than nine digits.

315-316

Transmitter Country

REQUIRED. Enter the transmitter country code. See General
Instruction 7 in Attachment C for information about the codes to
be entered.

317-332

Transmitter
Telephone Number

REQUIRED. Enter the transmitter telephone number. Enter all
numbers as a single number string without formatting and
punctuation such as spaces, hyphens, or parenthesis. Left justify
and space-fill the entry.

333-482

Transmitter Contact
Name

150

REQUIRED. Enter the name of an official contact for the
transmitter. Left justify and space-fill the entry.

REQUIRED. Enter "1A."

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Field
Position(s)

Field Name

Length

483-507

Transmitter Taxpayer
Identification Number
(TIN)

REQUIRED. Enter the U.S. or foreign Taxpayer Identification
Number (TIN) assigned to the transmitter. Do not enter
hyphens, slashes, or invalid entries such as all nines, all zeros,
or "123456789". Left justify and space-fill the entry.

508-515

Coverage Beginning
Date

REQUIRED. Enter the date of the earliest original transaction on
the file. Enter as a numeric 8-position entry in the format
MMDDCCYY where MM = month, DD = day, CC = century, and
YY = year.

516-523

Coverage Ending Date

REQUIRED. Enter the date of the latest original transaction on
the file. Enter as a numeric 8-position entry in the format
MMDDCCYY where MM = month, DD = day, CC = century, and
YY = year.

524-531

Transmitter Control
Code (TCC)

REQUIRED. Enter the assigned 8-character production
Transmitter Control Code (TCC). Do not enter a TCC assigned
for testing purposes.

532-534

Batch Sequence
Number (BSN)

Space-fill this field, which is reserved for BSA E-Filing use.

535-1186

Filler

1187-1190

Format Indicator

Space-fill this field, which is reserved for BSA E-Filing use.

1191-1200

User Field

Use this field for any descriptive information you may require;
otherwise space-fill this field.

652

Description and Remarks

Space-filled.

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Filing Institution Information (2A) Record – Required
This record identifies information regarding the filing institution. The number of 2A records
will depend on the number of different filing institutions that are included on the file. The 2A
record item numbers refer to the FinCEN SAR Part IV Items 78 - 91.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "2A."

3-4

Part IV Primary
Federal Regulator
(Item 78)

REQUIRED. Enter the filing institution’s “Primary Federal
Regulator” code for the federal regulator or BSA examiner with
primary responsibility for monitoring the filing institution's
Bank Secrecy Act compliance. Filing institutions which are
government agencies or which are financial institutions not
subject to U.S. law should enter "Z" for not applicable. Left
justify and space-fill this entry.
Code Regulator/Examiner
A
Commodities Futures Trading Commission (CFTC)
B
Federal Reserve Board (FRB)
C
Federal Deposit Insurance Corporation (FDIC)
D
Internal Revenue Service (IRS)
E
National Credit Union Administration (NCUA)
F
Office of the Comptroller of the Currency (OCC)
G
Securities and Exchange Commission (SEC)
H
Federal Housing Finance Agency (FHFA)
Z
Not Applicable.

5-154

Part IV Filer Name
(Item 79)

150

REQUIRED. Enter the legal name of the filing institution as
recorded on articles of incorporation or other documents
establishing the institution. Left justify and space-fill the entry.

155-179

Part IV TIN (Item 80)

REQUIRED. Enter the U.S. or foreign Taxpayer Identification
Number (TIN) assigned to the filing institution. Do not enter
hyphens, slashes, alpha characters, or invalid entries such as all
nines, all zeros, or "123456789". A TIN entry is also invalid if it
is not equal to nine numbers and Part IV TIN Type is “A” or
“B.” Left justify and space-fill the entry.

180

Part IV TIN Type
(Item 81)

REQUIRED. Enter the filing institution TIN type as follows:
Code Description
A
EIN
B
SSN/ITIN
C
Foreign

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Field
Position(s)

Field Name

Length

Description and Remarks

181

Part IV Type of
Financial Institution
(Item 82)

REQUIRED. Enter the code that describes the filing institution.
If ‘Z’ is entered, a brief description of the institution type must
be entered in “Type of Financial Institution Other.”
Code Description
A
Casino/Card Club
B
Depository institution
C
Insurance company
D
MSB
E
Securities/Futures
F
Loan or Finance Company
G
Housing GSE
Z
Other

182-231

Part IV Type of
Financial Institution Other (Item 82)

REQUIRED (conditional). If "Type of Financial Institution" is
"Z," describe the type. Left justify and space-fill the entry.
Otherwise space-fill this field.

232-244

Part IV Type of
Securities and Futures
Institution (Item 83)

REQUIRED (conditional). If "Type of Institution" is "E," enter all
codes that describe the institution. Left justify and space-fill the
entry. DO NOT enter spaces between multiple entries.
Otherwise space-fill this field.
Code Description
A
Clearing broker-securities
B
CPO/CTA
C
Futures Commission Merchant
D
Holding company
E
Introducing broker-commodities
F
Introducing broker-securities
G
Investment Adviser
H
Investment company
I
Retail foreign exchange dealer
J
SRO Futures
K
SRO Securities
L
Subsidiary of financial/bank holding company
Z
Other

245-294

Part IV Type of
Securities and Futures
Institution - Other
(Item 83)

REQUIRED (conditional). If "Securities and Futures Institution
Type" contains "Z," enter a brief description left justified and
space-filled. Otherwise space-fill this field.

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Field
Position(s)

Field Name

Length

Description and Remarks

295

Part IV Financial
Institution
Identification Type
(Item 84)

Enter the "Financial Institution Identification Type" code from
the following list. Space-fill if no entry.
Code Description
A
Central Registration Depository (CRD) number
B
Investment Advisor Registration Depository (IARD)
number
C
National Futures Association (NFA) number
D
Research, Statistics, Supervision, and Discount (RSSD)
number
E
Securities and Exchange Commission (SEC) number
F
National Association of Insurance Commissioners
(NAIC Code)
G
Mortgage (NMLS ID)

296-315

Part IV Financial
Institution
Identification
Number (Item 84)

REQUIRED (conditional). Enter the filing institution’s
identification number if a code was entered in "Financial
Institution Identification Type." Left justify and space-fill this
entry. Otherwise space-fill the field.

316-415

Part IV Address (Item
85)

100

REQUIRED. Enter the filing institution street address or
equivalent. Left justify and space-fill the entry.

416-465

Part IV City (Item 86)

REQUIRED. Enter the filing institution city. Left justify and
space-fill the entry.

466-468

Part IV State (Item 87)

REQUIRED (conditional). Enter the filing institution state code
if the “Part IV Country” entry is "CA," "MX," or "US." See
General Instruction 7 in Attachment C for information about
the codes to be entered. Left justify and space-fill the entry.
Otherwise space-fill this field.

469-477

Part IV ZIP/Postal
Code (Item 88)

REQUIRED. Enter the filing institution ZIP Code or foreign
postal code. Do not include punctuation or formatting such as
hyphens, periods, and spaces within the entry. An entry must
be five or nine digits if the "Part IV Country" entry is "US." A
nine-digit entry cannot end with four zeros or four nines if the
"Part IV Country" entry is "US." Left justify and space-fill the
entry if less than nine characters.

478-479

Part IV Country (Item
89)

REQUIRED. Enter the filing institution country code. See
General Instruction 7 in Attachment C for information about
the codes to be entered.

480-629

Part IV Alternate
Name (Item 90)

150

Enter the filing institution’s alternate name (e.g., AKA individual or trade name, DBA - entity). Do not include “AKA”
or “DBA” with the entry. Left justify and space-fill the entry.
Space-fill if no entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

630-1190

Filler

561

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

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Financial Institution Where Activity Occurred (2B) Record –
Required
This record identifies information regarding the financial institution where the suspicious
activity occurred. The number of 2B records will depend on the number of different financial
institutions involved in each FinCEN SAR reported on the file. The 2B record item numbers
refer to the FinCEN SAR Part III, Items 47-63 and the “if no branch activity” box in Item 65.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "2B."

3-12

Financial Institution
Location Code

REQUIRED. Enter a unique numeric code for the different
financial institution locations involved with FinCEN SARs.
Right justify and zero-fill the entry.

Part III Type of
Financial Institution
(Item 47)

REQUIRED. Enter the financial institution type code from the
following list.
Code Description
A
Casino/Card Club
B
Depository institution
C
Insurance company
D
MSB
E
Securities/Futures
F
Loan or Finance Company
G
Housing GSE
Z
Other

14-63

Part III Type of
Financial Institution Other Description
(Item 47)

REQUIRED (conditional). If the "Type of Financial Institution”
is "Z", briefly describe the type. Left justify and space-fill the
entry. Space-fill if no entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

64-65

Part III Primary
Federal Regulator
(Item 48)

REQUIRED. Enter the financial institution Primary Federal
Regulator code for the federal regulator or BSA examiner with
primary responsibility for monitoring the financial institution's
Bank Secrecy Act compliance. Enter "Z" for not applicable if the
financial institution is a foreign financial institution not subject
to U.S. law. Left justify and space-fill the entry.
Code Regulator/Examiner
A
Commodities Futures Trading Commission (CFTC)
B
Federal Reserve Board (FRB)
C
Federal Deposit Insurance Corporation (FDIC)
D
Internal Revenue Service (IRS)
E
National Credit Union Administration (NCUA)
F
Office of the Comptroller of the Currency (OCC)
G
Securities and Exchange Commission (SEC)
H
Federal Housing Finance Agency (FHFA)
Z
Not Applicable.

Part III Type of
Gaming Institution
(Item 49)

REQUIRED (conditional). If the "Type of Financial Institution"
is “A - Casino/Card Club” enter the gaming institution type
code from the following list, Space-fill if no entry.
Code Description
A
State licensed casino
B
Tribal authorized casino
C
Card club
Z
Other

67-69

Filler

Space-filled for future use.

70-119

Part III Type of
Gaming Institution Other (Item 49)

REQUIRED (conditional). If the "Type of Gaming Institution" is
"Z," enter a brief description, left justified and space-filled.
Space-fill if no entry.

120-129

Part III Type of
Securities and Futures
Institution (Item 50)

REQUIRED (conditional). If the "Type of Financial Institution"
is “E - Securities/Futures," enter the securities and futures type
code(s) from the following list. Enter all codes that apply, left
justified and space-filled. DO NOT enter spaces between
multiple entries. Space-fill if no entries.
Code Description
A
Clearing broker-securities
B
Futures Commission Merchant
C
Holding company
D
Introducing broker-commodities
E
Introducing broker-securities
F
Investment Adviser
G
Investment company
H
Retail foreign exchange dealer
I
Subsidiary of financial/bank holding company
Z
Other

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

130-179

Securities and Futures
Institution Type Other Description
(Item 50)

REQUIRED (conditional). If the "Type of Securities and Futures
Institution" contains "Z," briefly describe the type, left justified
and space-filled. Space-fill if no entry.

180

Part III Financial
Institution
Identification Type
(Item 51)

181-200

Part III Financial
Institution
Identification
Number (Item 51)

REQUIRED (conditional). Enter the financial institution’s
identification number if a code was entered in "Financial
Institution Identification Type." left justified and space-filled.
Space-fill of no entry.

201

Part III Financial
Institution’s Role in
Transaction (Item 52)

Enter the code that describes the financial institution role in the
transaction. Space-fill if no entry.
Code Description
A
Selling location
B
Paying location
C
Both a & b

202-351

Part III Legal Name of
Financial Institution
(Item 53)

150

REQUIRED (conditional). Enter the financial institution’s legal
name, left justified and space-filled. Space-fill if “Part III Legal
Name of Financial Institution Unknown” contains “X.”

352

Part III Legal Name of
Financial Institution
Unknown (Item 53)

If the legal name of the financial institution is unknown, enter
"X". Otherwise space-fill this field.

353-502

Part III Alternate
Name (Item 54)

150

Enter the financial institution’s alternate name, left justified and
space-filled. Space-fill if no entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

503-527

Part III TIN (Item 55)

REQUIRED (conditional). Enter the financial institution’s U.S.
or foreign Taxpayer Identification Number (TIN). Do not enter
hyphens, slashes, alpha characters, or invalid entries such as all
nines, all zeros, or "123456789." A TIN entry is also invalid if it
is not equal to nine numbers and Part III TIN Type is “A” or
“B.” Left justify and space-fill the entry. Space-fill if Part III TIN
Unknown” contains “X.”

528

Part III TIN Unknown
(Item 55)

If the financial institution’s TIN is unknown, enter "X."
Otherwise space-fill this field.

529

Part III TIN Type
(Item 56)

REQUIRED (conditional). Enter the code for the financial
institution’s TIN type if “Part III TIN” contains an entry. Spacefill if “Part III TIN Unknown” contains "X." If a TIN has been
entered but the TIN type is unknown, follow the Item 56
instructions in Attachment C to determine the TIN Type code
to enter.
Code
A
B
C

Description
EIN
SSN/ITIN
Foreign

530-629

Part III Address (Item
57)

100

REQUIRED (conditional). Enter the financial institution’s street
address, left justified and space-filled. Space-fill if “Part III
Address Unknown” contains “X.”

630

Part III Address
Unknown (Item 57)

If the financial institution’s street address is unknown, enter
"X." Otherwise space-fill.

631-680

Part III City (Item 58)

REQUIRED (conditional). Enter the financial institution’s city,
left justified and space-filled. Space-fill “Part III City
Unknown” contains “X.”

681

Part III City
Unknown (Item 58)

If the financial institution’s city is unknown, enter ".X"
Otherwise space-fill.

682-684

Part III State (Item 59)

Enter the financial institution state code if the "Part III Country"
code is "US," "CA," or "MX." See General Instruction 7 in
Attachment C for information about the codes to be entered.
Left justify and space-fill a two-digit entry. Space-fill if "Part III
Country" is not "US," "CA," or "MX" or if the state is unknown.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

685-693

Part III ZIP/Postal
Code (Item 60)

REQUIRED (conditional). Enter the financial institution’s ZIP
Code or foreign postal code. Do not include punctuation or
formatting such as hyphens, periods, and spaces within the
entry. An entry must be five or nine digits if the "Part III
Country" entry is "US." A nine-digit entry cannot end with four
zeros or four nines if the "Part III Country" entry is "US." Left
justify and space-fill this entry if less than nine digits. Space-fill
if the "Part III Country" entry is not “US,” “CA,” or “MX,” or if
“Part III ZIP/Postal Code Unknown” contains “X.”

694

Part III ZIP/Postal
Code Unknown (Item
60)

If the financial institution ZIP Code or foreign postal code is
unknown, enter "X." Otherwise space-fill this field.

695-696

Part III Country (Item
61)

REQUIRED (conditional). Enter the financial institution’s
country code. See General Instruction 7 in Attachment C for
information about the codes to be entered. Space-fill if “Part III
Country Unknown” contains “X.”

697

Part III Country
Unknown (Item 61)

If the financial institution’s country is unknown, enter "X."
Otherwise space-fill this field.

698-717

Part III Internal
Control/File Number
(Item 62)

Enter the financial institution’s Internal Control/File Number
for the FinCEN SAR being reported. Left justify and space-fill
the entry. Space-fill if no number entered.

718-732

Part III Loss to
Financial Institution
(Item 63)

Enter the loss (in U.S. Dollars) to the financial institution where
the activity occurred. This loss cannot be greater than the
amount recorded in Item 26 for the amount involved in this
report. Right justify and zero-fill this entry. Space-fill if no loss
is recorded. The entry “0” for the amount of loss is NOT
permitted in this item. See the Item 63 instructions in
Attachment C for further information on entering amounts in
this item.

733

Part III No Branch
Activity (Item 65)

Enter "X" if no branch or office belonging to the financial
institution was involved in the suspicious activity. There must
be no Branch Office Information (2C) Records associated with
this 2B record in the file. Otherwise space-fill this field.

734-1190

Filler

457

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

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Financial Crimes Enforcement Network

Branch or Office Institution Where Activity Occurred (2C)
Record
This record identifies information regarding the branch or office institution where the
suspicious activity occurred. The number of 2C records will depend on the number of different
branch or office locations where the suspicious activity occurred for each FinCEN SAR in the
file. The 2C record item numbers refer to the FinCEN SAR Part III, Items 64-77. If “Part III No
Branch Activity” within the 2B record contains “X,” then there will be no 2C record recorded for
the FinCEN SAR in the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "2C."

3-12

Branch or Office
Location Code

REQUIRED. Enter a unique numeric code for the different
branch or office locations involved with FinCEN SARs. Right
justify and zero-fill the entry.

Part III Branch’s Role
in Transaction (Item
64)

Enter the appropriate code to describe the branch's role in the
transaction. Space-fill if no code is appropriate.
Code Description
A
Selling location
B
Paying location
C
Both a & b

14-113

Part III Address of
Branch or Office (Item
65)

100

Enter the branch or office street address, left justified and
space-filled. Space-fill if the street address is unknown.

114-163

Part III Branch or
Office City (Item 67)

Enter the branch or office city, left justified and space-filled.
Space-fill if unknown.

164-166

Part III Branch or
Office State (Item 68)

Enter the branch or office state code if the "Branch or Office
Country" code is "US," "CA," or "MX." See General Instruction 7
in Attachment C for information about the codes to be entered.
Space-fill if unknown.

167-175

Part III Branch or
Office ZIP/Postal
Code (Item 69)

Enter the branch or office ZIP Code or foreign postal code. Do
not include punctuation or formatting such as hyphens,
periods, and spaces within the entry. An entry must be five or
nine digits if the "Branch or Office Country" entry is "US." A
nine-digit entry cannot end with four zeros or four nines if the
"Branch or Office Country" entry is "US." Left justify and spacefill this entry if less than nine digits. Space-fill if unknown.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

176-177

Part III Branch or
Office Country (Item
70)

REQUIRED. Enter the branch or office country code.

178-197

Part III Branch or
Office RSSD Number
(Item 66)

Enter the branch or office RSSD number, left justified and
space-filled. Space-fill if no number entered.

198-1190

Filler

993

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

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Financial Crimes Enforcement Network

Suspicious Activity Information (3A) Record – Required
This record identifies information regarding the suspicious activity. The number of 3A records
will depends on the number of different FinCEN SARs included on the file. The 3A record may
only occur one time per FinCEN SAR. The 3A record item numbers refer to the FinCEN SAR
Item 1, Part II Items 26-40, and Part IV, Items 92-98.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3A."

3-7

Transaction Sequence
Number

REQUIRED. Enter a sequential number starting with 00001 and
increment by 1 for each suspicious activity (3A) record.

Attachment Indicator

Enter "X" if the suspicious activity is associated with an
attachment. Please see Attachment D – Batch Attachments for
formatting and submission instructions. Space-fill if no
attachment is associated with the FinCEN SAR.

Type of Filing (Item 1)

REQUIRED (conditional). Enter “A” if the report is an initial
report. Enter “B” if the report is a corrected or amended report.
If neither applies, then this field must be space-filled and “C”
must be entered in the following “Continuing Activity Report”
field. If “A” for initial report is entered and the FinCEN SAR is
a joint report, then “D” must be entered in “Joint Report.” If
“B” for corrected/amended report is entered and the prior
report was a continuing report and/or joint report, then
“Continuing Activity Report” and/or “Joint Report” must
contain entries as appropriate.
Code Description
A
Initial report
B
Correct/Amend prior report

Continuing Activity
Report (Item 1)

REQUIRED (conditional). If the filing is a continuing activity
report, enter “C.” Otherwise space-fill this field.

Joint Report (Item 1)

If the filing is a joint report, enter “D.” Either “Type of Filing”
or “Continuing Activity Report” must contain an entry.
Otherwise space-fill this field.

12-25

Prior Report
Document Control
Number/ BSA
Identifier (Item 1)

REQUIRED (conditional). If the "Filing Type" is "B
Correct/Amend prior report” or "C Continuing activity report”,
enter the prior report Document Control Number (DCN) or
BSA Identifier (BSA ID). If the DCN or BSA ID is unknown,
enter zeros in place of the unknown number. Space-fill if no
entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

26-40

Amount Involved In
This Report (Item 26)

REQUIRED (conditional). Enter the amount (in U.S. Dollars)
involved in the suspicious activity. Right justify and zero-fill
this entry. Zero is not an amount, so the entry “0” for the
amount involved is NOT permitted in this item. Space-fill if
the amount is unknown or no amount is involved.

Amount Unknown or
No Amount Involved
(Item 26)

If the amount involved in the suspicious activity is unknown or
no amount is involved, enter the appropriate code from the
following list. Otherwise space-fill this field.
Code Description
A
Amount unknown
B
No Amount involved

42-49

Date or Date Range of
Suspicious Activity From (Item 27)

REQUIRED. Enter the suspicious activity date or beginning
suspicious activity date (if reporting a range of suspicious
activity dates). Enter as a numeric 8-position field in the format:
month, day, century, year (MMDDCCYY). This date cannot be
greater than "Date Filed (Item 98).”

50-57

Date or Date Range of
Suspicious Activity To (Item 27)

Enter the most-recent date of the suspicious activity (if
including a range of suspicious activity dates). Enter as a
numeric 8-position field in the format: month, day, century,
year (MMDDCCYY). This date cannot be earlier that the "Date
or Date Range of Suspicious Activity - From (Item 27)” or
greater than "Date Filed (Item 98).” Space-fill if no date entered.

58-72

Cumulative Amount
(Item 28)

If "Continuing Activity Report" contains “C,” enter the
cumulative aggregated total U.S. Dollar amount involved for
all SARs filed on the suspicious activity. The cumulative
aggregated total dollar amount must be greater than or equal to
the “Amount Involved In This Report.” Enter a zero (0) if the
amount is unknown or no amount is involved and “Continuing
Activity Report” contains “C.” See the Item 28 instructions in
Attachment C for additional information on entering amounts
in this field. Otherwise space-fill this field.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

73-79

Structuring (Item 29)

Enter the appropriate code(s) to identify suspicious activity
that relates to structuring (check all that apply). Left justify and
space-fill the entry. Do not include spaces between multiple
entries. Space-fill if no entry.
Code Description
A
Alters transaction to avoid BSA recordkeeping
requirement
B
Alters transaction to avoid CTR requirement
C
Customer cancels transaction to avoid BSA reporting
and recordkeeping requirements
D
Multiple transactions below BSA recordkeeping
threshold
E
Multiple transactions below CTR threshold
F
Suspicious inquiry by customer regarding BSA
reporting or recordkeeping requirements
Z
Other

80-129

Structuring - Other
Description (Item 29)

REQUIRED (conditionally). If "Structuring" contains “Z,” enter
a brief description of the activity. Left justify and space-fill this
entry. Space-fill if no entry.

130-131

Terrorist Financing
(Item 30)

Enter the appropriate code(s) to identify suspicious activity
that relates to terrorist financing (check all that apply). Left
justify and space-fill the entry. Do not include spaces between
multiple entries. Space-fill if no entry.
Code Description
A
Known or suspected terrorist/terrorist organization
Z
Other

132-181

Terrorist Financing Other Description
(Item 30)

REQUIRED (conditionally). If the "Terrorist Financing"
contains “Z,” enter a brief description of the activity. Left
justify and space-fill the entry. Space-fill if no entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

182-192

Fraud (Item 31)

Enter the appropriate code(s) to identify suspicious activity
that relates to fraud (check all that apply). Left justify and
space-fill the entry. Do not include spaces between multiple
entries. Space-fill if no entry.
Code
Description
A
ACH
B
Business loan
C
Check
D
Consumer loan
E
Credit/Debit card
F
Healthcare
G
Mail
H
Mass-marketing
I
Pyramid scheme
J
Wire
Z
Other

193-242

Fraud - Other
Description (Item 31)

REQUIRED (conditionally). If "Fraud" contains “Z,” provide a
brief description of the activity. Left justify and space-fill this
entry. Space-fill if no entry.

243-247

Casinos (Item 32)

Enter the appropriate code(s) to identify suspicious activity
that relates to casinos (check all that apply). Left justify and
space-fill the entry. Do not include spaces between multiple
entries. Space-fill if no entry.
Code
Description
A
Inquiry about end of business day
B
Minimal gaming with large transactions
C
Suspicious intra-casino funds transfers
D
Suspicious use of counter checks or markers
Z
Other

248-297

Casinos - Other
Description (Item 32)

REQUIRED (conditionally). If "Casinos" contains “Z,” provide
a brief description of the activity. Left justify and space-fill this
entry. Space-fill if no entry.

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

298-310

Money Laundering
(Item 33)

Enter the appropriate code(s) to identify suspicious activity
that relates to money laundering (check all that apply). Left
justify and space-fill the entry. Do not include spaces between
multiple entries. Space-fill if no entry.
Code Description
A
Exchanges small bills for large bills or vice versa
B
Suspicion concerning the physical condition of funds
C
Suspicion concerning the source of funds
D
Suspicious designation of beneficiaries, assignees or
joint owners
E
Suspicious EFT/wire transfers
F
Suspicious exchange of currencies
G
Suspicious receipt of government payments/benefits
H
Suspicious use of multiple accounts
I
Suspicious use of noncash monetary instruments
J
Suspicious use of third-party transactors (straw-man)
K
Trade Based Money Laundering/Black Market Peso
Exchange
L
Transaction out of pattern for customer(s)
Z
Other

311-360

Money Laundering –
Other Description
(Item 33)

REQUIRED (conditionally). If "Money Laundering" contains
“Z,” provide a brief description of the activity. Left justify and
space-fill this entry. Space-fill if no entry.

361-366

Identification /
Documentation
(Item 34)

Enter the appropriate code to identify suspicious activity that
relates to identification or documentation (check all that apply).
Left justify and space-fill the entry. Do not include spaces
between multiple entries. Space-fill if no entry.
Code
Description
A
Changes spelling or arrangement of name
B
Multiple individuals with same or similar identities
C
Provided questionable or false documentation
D
Refused or avoided request for documentation
E
Single individual with multiple identities
Z
Other

367-416

Identification /
Documentation Other Description
(Item 34)

REQUIRED (conditionally). If "Identification / Documentation"
contains “Z,” provide a brief description of the activity. Left
justify and space-fill this entry. Space-fill if no entry.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

417-435

Other Suspicious
Activities (Item 35)

Enter the appropriate code to identify other suspicious activity
(check all that apply). Left justify and space-fill the entry. Do
not include spaces between multiple entries. Space-fill if no
entry.
Code
Description
A
Account takeover
B
Bribery or gratuity
C
Counterfeit instruments
D
Elder financial exploitation
E
Embezzlement/theft/disappearance of funds
F
Forgeries
G
Identity theft
H
Little or no concern for product performance
penalties, fees, or tax consequences
I
Misuse of “free look”/cooling-off/right of rescission
J
Misuse of position or self-dealing
K
Suspected public/private corruption (domestic)
L
Suspected public/private corruption (foreign)
M
Suspicious use of informal value transfer system
N
Suspicious use of multiple transaction locations
O
Transaction with no apparent economic, business, or
lawful purpose
P
Two or more individuals working together
Q
Unauthorized electronic intrusion
R
Unlicensed or unregistered MSB
Z
Other

436-485

Other Suspicious
Activities - Other
Description (Item 35)

REQUIRED (conditionally). If "Other Suspicious Activity"
contains “Z,” provide a brief description of the activity. Left
justify and space-fill this entry. Space-fill if no entry.

486-492

Insurance (Item 36)

Enter the appropriate code to identify suspicious activity that
relates to insurance (check all that apply). Left justify and
space-fill the entry. Do not include spaces between multiple
entries. Space-fill if no entry.
Code
Description
A
Excessive insurance
B
Excessive or unusual cash borrowing against
policy/annuity
C
Proceeds sent to or received from unrelated third
party
D
Suspicious life settlement sales insurance
(e.g.,STOLI’s, Viaticals)
E
Suspicious termination of policy or contract
F
Unclear or no insurable interest
Z
Other

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

493-542

Insurance - Other
Description (Item 36)

REQUIRED (conditionally). If "Insurance" contains “Z,”
provide a brief description of the activity. Left justify and
space-fill this entry. Space-fill if no entry.

543-547

Securities/Futures/Op
tions (Item 37)

Enter the appropriate code to identify suspicious activity that
relates to securities, futures, or options (check all that apply).
Left justify and space-fill the entry. Do not include spaces
between multiple entries. Space-fill if no entry.
Code
Description
A
Insider trading
B
Market manipulation/wash trading
C
Misappropriation
D
Unauthorized pooling
Z
Other

548-597

Securities/Futures/Op
tions - Other
Description (Item 37)

REQUIRED (conditionally). If "Securities/Futures/Options"
contains “Z,” provide a brief description of the activity. Left
justify and space-fill this entry. Space-fill if no entry.

598-602

Mortgage Fraud (Item
38)

Enter the appropriate code to identify suspicious activity that
relates to mortgage fraud (check all that apply). Left justify and
space-fill the entry. Do not include spaces between multiple
entries. Space-fill if no entry.
Code
Description
A
Appraisal fraud
B
Foreclosure fraud
C
Loan Modification fraud
D
Reverse mortgage fraud
Z
Other

603-652

Mortgage Fraud Other Description
(Item 38)

REQUIRED (conditionally). If "Mortgage Fraud" contains “Z,”
provide a brief description of the activity. Left justify and
space-fill this entry. Left justify if no entry.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

653-672

Product Type(s)
Involved (Item 39)

Enter the code(s) for all product type(s) involved in the
suspicious activity (check all that apply). Left justify and spacefill the entry. Do not include spaces between multiple entries.
Space-fill if no entry.
Code
Description
A
Bonds/Notes
B
Commercial mortgage
C
Commercial paper
D
Credit card
E
Debit card
F
Forex transactions
G
Futures/Options on futures
H
Hedge fund
I
Home equity loan
J
Home equity line of credit
K
Insurance/Annuity products
L
Mutual fund
M
Options on securities
N
Penny stocks/Microcap securities
O
Prepaid access
P
Residential mortgage
Q
Security futures products
R
Stocks
S
Swap, hybrid, or other derivatives
Z
Other

673-722

Product Type(s)
Involved- Other
Description (Item 39)

REQUIRED (conditionally). If the “Product Type(s) Involved”
contains “Z,” briefly describe the product type involved.

723-732

Instrument
Type(s)/Payment
Mechanism(s)
Involved (Item 40)

Enter the code(s) for all Instrument Type(s)/Payment
Mechanism(s) involved in the suspicious activity (check all that
apply). Left justify and space-fill the entry. Do not include
spaces between multiple entries. Space-fill if no entry.
Code
Description
A
Bank/Cashier's check
B
Foreign currency
C
Funds transfer
D
Gaming instruments
E
Government payment
F
Money orders
G
Personal/Business check
H
Travelers checks
I
U.S. Currency
Z
Other

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
26

Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

733-782

Instrument
Type(s)/Payment
Mechanism(s)
Involved - Other
Description (Item 40)

REQUIRED (conditionally). If "Instrument Type(s)/Payment
Mechanism(s) Involved" contains “Z,” briefly describe the
product type(s) involved. Left justify and space-fill this entry.
Space-fill if no entry.

783-932

LE Contact Agency
(Item 92)

150

Enter the name of the law enforcement (LE) agency contacted
by the filing institution. Left justify and space-fill this entry.
Space-fill if no entry.

933-1082

LE Contact Name
(Item 93)

150

Enter the name of the individual contacted at the law
enforcement agency. Left justify and space-fill this entry. Spacefill if no entry.

1083-1098

LE Contact Telephone
Number (Item 94)

Enter the law enforcement agency contact telephone number.
Left justify and space-fill this entry. Space-fill if no entry.

1099-1104

LE Contact Telephone
Extension (Item 94)

Enter the law enforcement contact telephone number extension.
Left justify and space-fill this entry. Space-fill if no entry.

1105-1112

LE Contact Date
(Item 95)

Enter the date the filing institution first contacted the law
enforcement agency. Enter as a numeric 8-position field in
format: month, day, century, year (MMDDCCYY). Space-fill if
no entry.

1113-1122

Filing Institution
Contact Office (Item
96)

REQUIRED. Enter the name of the contact office designated by
the filing institution to provide information about this report.
Left justify and space-fill the entry.

1123-1138

Filing Institution
Phone Number (Item
97)

REQUIRED. Enter the telephone number of the contact office
designated by the filing institution to provide information
about this report. Do not include formatting such as spaces,
hyphens, or parenthesis. Left justify and space-fill this entry.

1139-1144

Filing Institution
Phone Number
Extension (Item 97)

Enter the telephone extension (if any) of the contact office
designated by the filing institution to provide information
about this report. Left justify and space-fill this entry. Space-fill
if no entry.

1145-1152

Date Filed (Item 98)

REQUIRED. Record the date filed as a numeric 8-position field
in format: month, day, century, year (MMDDCCYY).

1153-1172

Internal Control/
File Number (Item 91)

Enter the filing institution Internal Control/File Number
assigned to this report. Left justify and space-fill the entry.
Space-fill if no entry.

1173-1190

Filler

Space-filled.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Commodity Type (3B) Record
This record identifies information regarding the commodity type(s) involved in a suspicious
activity. A maximum of 99 3B records may be associated with a Suspicious Activity Information
(3A) Record. The 3B record item number refers to the FinCEN SAR Part II, Item 41. If no
commodity type information is being reported there will be no 3B record for the FinCEN SAR in
the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3B."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-57

Commodity Type
(Item 41)

Enter the commodity type if a commodity is involved in the
suspicious activity. Left justify and space-fill the entry.

58-1190

Filler

1133

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Product/Instrument Description (3C) Record
This record identifies information regarding the product/instrument description(s) involved in a
suspicious activity. A maximum of 99 3C records may be associated with a Suspicious Activity
Information (3A) Record. The 3C record item number refers to the FinCEN SAR Part II, Item 42.
If no product or instrument description is being reported there will be no 3C record for the
FinCEN SAR in the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3C."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-57

Product/Instrument
Description (Item 42)

Enter a description of the product reported in Item 39 "Product
Type(s) Involved" or the instrument recorded in Item 40
"Instrument Type(s)/Payment Mechanism(s) Involved". Left
justify and space-fill this entry.

58-1190

Filler

1133

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Market Where Traded (3D) Record
This record identifies information regarding the market(s) where traded involved in a
suspicious activity. A maximum of 99 3D records may be associated with a Suspicious Activity
Information (3A) Record. The 3D record item number refers to the FinCEN SAR Part II, Item 43.
If no market where traded is being reported there will be no 3D record for the FinCEN SAR in
the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3D."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-12

Market Where Traded
(Item 43)

Enter the three to five letter code for the market where the
"Product Type(s) Involved" reported in Item 39 or the
"Commodity Type" reported in Item 41 was traded. Use only
the ISO 10383 Exchange/Market Identifier (MIC) Codes found
at http://www.iso15022.org/MIC/homepageMIC.htm. Left
justify and space-fill the entry.

13-1190

Filler

1178

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

IP Address (3E) Record
This record identifies information regarding the IP address(s) involved in a suspicious activity.
A maximum of 99 3E records may be associated with a Suspicious Activity Information (3A)
Record. The 3E record item number refers to the FinCEN SAR Part II, Item 44. If no IP address is
being reported there will be no 3E record for the FinCEN SAR in the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3E."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-46

IP Address (Item 44)

Enter the IP address connected to the suspicious activity. If the
IP address is IPv4, use a variation of the format
nnn.nnn.nnn.nnn (n = number) with periods between the
segments. If the IP address is IPv6, use a variation of the format
cccc:cccc:cccc:cccc:cccc:cccc:cccc:cccc (c = character, IPv6 is
alphanumeric in some segments) with colons between the
segments. Left justify and space-fill the entry.

47-1190

Filler

1144

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

CUSIP Number (3F) Record
This record identifies information regarding the CUSIP Number(s) involved in a suspicious
activity. A maximum of 99 3F records may be associated with a Suspicious Activity Information
(3A) Record. The 3F record item number refers to the FinCEN SAR Part II, Item 45. If no CUSIP
Number is being reported there will be no 3F record for the FinCEN SAR in the file.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "3F."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-19

CUSIP Number (Item
45)

Enter the CUSIP Number of any securities product involved in
the suspicious activity. Left justify and space-fill this entry.

20-1190

Filler

1171

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Subject (4A) Record – Required
This record contains information related to the subject’s identity. A maximum of 999 4A records
may be associated with a Suspicious Activity Information (3A) Record. If all critical* subject
information is unavailable, enter “B” in Field Position 9 of the Subject (4A) Record, and spacefill Items 3-20. NOTE: If there are no known accounts associated with the subject, enter "X" in
Item 24, Field Position 342. If this field position is space-filled, there must be at least one
"Subject - Affected TIN & Account Number (4I) Record” for the associated Subject (4A) Record.
The 4A record item numbers refer to the FinCEN SAR Part I, Items 2-5, 7, 13-16, 20, & 24-25.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4A."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

If Entity (Item 2a)

If the subject is an entity, enter “A.” Otherwise space-fill this
field.

If All Critical* Subject
Information Is
Unavailable (Item 2b)

If all critical subject information is unavailable other than Item
24, enter ”B.”All required items other than Item 24 must be
space-filled if this field contains “B.” Otherwise space-fill this
field.

10-159

Individual’s Last
Name or Entity’s
Legal Name (Item 3)

150

REQUIRED (conditional). Enter the last name of an individual
or the legal name of an entity. Left justify and space-fill this
entry. Space-fill if “Individual’s Last Name or Entity’s Legal
Name Unknown” contains “X.”

160

Individual’s Last
Name or Entity’s
Legal Name
Unknown (Item 3)

If the last name or legal name is unknown and Field Position 9
is space filled, enter "X." Otherwise space-fill this field.

161-195

First Name (Item 4)

REQUIRED (conditional). Enter the individual’s first name. Left
justify and space-fill this entry. Space-fill if “First Name
Unknown” contains “X,” “If Entity” contains “A,” or “If All
Critical* Subject Information Is Unavailable” contains “B.”

196

First Name Unknown
(Item 4)

If the individual's first name is unknown and Field Position 9 is
space filled, enter "X." Otherwise space-fill this field.

197-231

Middle Name or
Middle Initial (Item 5)

Enter the individual’s middle name or middle initial. Left
justify and space-fill this entry. Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

232-266

Suffix (Item 5)

Enter the subject name suffix, e.g. JR, SR, III, etc. Left justify and
space-fill this entry. Otherwise space-fill this field.

267

Gender (Item 5a)

Enter the code for the individual’s gender from the list below.
Otherwise space-fill this field. NOTE: Item 5a does not create
an obligation for a financial institution to collect this data when
such collection would be in conflict with the financial
institution’s obligations under any other federal law.
Code
Description
A
Male
B
Female
C
Unknown

268-297

Occupation or Type
of Business (Item 7)

Enter the subject's occupation or type of business. Left justify
and space-fill this entry. Otherwise space-fill this field.

298-303

NAICS Code (Item 7)

Enter the NAICS Code for the subject’s occupation or type of
business. Use only the codes from the NAICS Code list found
on the BSA E-Filing Web Site
(http://bsaefiling.fincen.treas.gov/main.html). Use of codes not
found on that list is prohibited. Left justify and space-fill this
entry. Otherwise space-fill this field.

304-328

TIN (Item 13)

REQUIRED (conditional). Enter the subject's U.S. or foreign
Taxpayer Identification Number (TIN). Do not enter hyphens,
slashes, alpha characters, or invalid entries such as all nines, all
zeros, or "123456789". A TIN entry is also invalid if it is not
equal to nine numbers and TIN Type is “A” or “B.”Left justify
and space-fill the entry. Space-fill if “TIN Unknown” contains
“X.”

329

TIN Unknown (Item
13)

If the subject's TIN is unknown and Field Position 9 is space
filled, enter "X." Otherwise space-fill this field.

330

TIN Type (Item 14)

REQUIRED (conditional). Enter the code for the subject's TIN
Type from the following list if a TIN has been recorded. Follow
Item 14 instructions in Attachment C for recording a TIN Type
when a TIN was provided but the TIN Type is unknown.
Otherwise space-fill this field.
Code
Description
A
EIN
B
SSN/ITIN
C
Foreign

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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

331

Form of Identification
for Subject Unknown
(Item 15)

If the subject's identification is unknown and Field Position 9 is
space filled, enter "X." Otherwise space-fill this field. If this field
is space-filled and Field Position 9 does not contain “B,” there
must be at least one “Subject Identification (4C) Record”
associated with this subject.

332-339

Date of Birth (Item 16)

REQUIRED (conditional). Record the individual's date of birth
as a numeric 8-position entry in the format MMDDCCYY
where MM = month, DD = day, CC = century, and YY = year. If
the birth day and or month is unknown, enter “00” for the
unknown day or month. Space fill this field if “Date of Birth
Unknown” contains “X” or if Item 2a “If Entity” contains “A.”

340

Date of Birth
Unknown (Item 16)

If the individual's date of birth is unknown and Field Position 9
is space-filled, enter "X." Space fill this field if the individual’s
date of birth is known or if Item 2a “If Entity” contains “A.”

341

Corroborative
Statement to Filer?
(Item 20)

Indicate whether or not the filer received a corroborative
statement from the individual by selecting the appropriate code
(enter only one). Otherwise space-fill this field.
Code
Description
A
Yes
B
No

342

No Known Account
Involved (Item 24)

If there are no known accounts associated with the subject enter
"X." Otherwise space-fill. If this field position is space-filled,
there must be at least one "Affected TIN & Account Number
(4I) Record” in this file associated with the subject.

343

Subject Role in
Suspicious Activity
(Item 25)

Record the subject's role in the suspicious activity if applicable.
Otherwise space-fill.
Code
Description
A
Purchaser/Sender
B
Payee/Receiver
C
Both a & b

344-1190

Filler

847

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Subject Address (4B) Record
This record contains information related to the subject’s address. A maximum of 99 4B records
may be associated with a Subject (4A) Record. If all critical information is unavailable for the
subject there will be no 4B record for the FinCEN SAR in the file. The 4B record item numbers
correspond to the FinCEN SAR Part I, Items 8-12.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4B."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-107

Part I Address (Item
8)

100

REQUIRED (conditional). Enter the subject's street address, left
justified and space-filled. Space fill if “Part I Address
Unknown” contains “X.”

108

Part I Address
Unknown (Item 8)

If the subject's street address is unknown, enter "X”. Otherwise
space-fill this field.

109-158

Part I City (Item 9)

REQUIRED (conditional). Enter the subject's city, left justified
and space-filled. Space fill if “Part I City Unknown” contains
“X.”

159

Part I City Unknown
(Item 9)

If the subject's city is unknown, enter "X”. Otherwise space-fill
this field.

160-162

Part I State (Item 10)

REQUIRED (conditional). Enter the two or three letter code for
the subject's state if the “Country” code is “US,” “CA,” or
“MX.” Left justify and space-fill this entry. See General
Instruction 7 in Attachment C for information about the codes
to be entered. Space fill if “Part I Country” is a code other than
“US,” “CA,” or “MX,” or if “Part I State Unknown” contains
“X.”

163

Part I State Unknown
(Item 10)

If the subject's state is unknown and Part I Country is “US,”
“CA,” “MX,” or unknown, enter "X”. Otherwise space-fill.

164-172

Part I ZIP/Postal
Code (Item 11)

REQUIRED (conditional). Enter the subject's ZIP Code or
foreign postal code. A nine-digit code cannot end with four
zeros or four nines if the “Country” entry is “US.” ZIP Codes
and foreign postal codes must be entered without formatting or
special characters such as spaces or hyphens. Left justify and
space-fill this entry. Space fill if “Part I ZIP/Postal Code
Unknown” contains “X.”

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

173

Part I ZIP/Postal
Code Unknown (Item
11)

If the subject's ZIP Code or foreign postal code is unknown,
enter "X”. Otherwise space-fill this field.

174-175

Part I Country (Item
12)

REQUIRED (conditional). Enter the two-letter code for the
subject's country. See General Instruction 7 in Attachment C for
information about the codes to be entered. Space fill if “Part I
Country Unknown” contains “X.”

176

Part I Country
Unknown (Item 12)

If the subject's country is unknown, enter "X.” Otherwise spacefill this field.

177-1190

Filler

1014

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Subject Identification (4C) Record
This record contains information related to the subject’s form of identification. A maximum of
99 4B records may be associated with a Subject (4A) Record. If all critical information is
unavailable for the subject, or the form of identification for the subject is unknown, there will be
no 4C record for the FinCEN SAR in the file. The 4C record item number corresponds to
FinCEN SAR Part I, Item 15.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4C."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

Form of Identification
- Type (Item 15)

REQUIRED. Enter the code from the following list that best
describes the subject’s identification.
Code
Description
A
Driver's license/State ID
B
Passport
C
Alien registration
Z
Other

9-32

Form of Identification
- Number (Item 15)

Enter the subject's identification number if known, left justified
and space-filled without formatting such as hyphens or spaces.
Otherwise space-fill this field.

33-35

Subject Identification
Issuing State (Item 15)

Enter the appropriate two or three character code when the
identification was issued by a known state, province, or
territory of the United States, Canada, or Mexico. See General
Instruction 7 in Attachment C for information about the codes
to be entered. Otherwise space-fill this field.

36-37

Subject Identification
Issuing Country (Item
15)

REQUIRED. Enter the appropriate code for the country, if
known, that issued the identification or where the identification
was issued. See General Instruction 7 in Attachment C for
information about the codes to be entered.

38-87

Subject Identification
- Other (Item 15)

REQUIRED (conditional). If "Form of Identification - Type"
contains "Z,” provide a description of the identification.
Otherwise space-fill this field.

88-1190

Filler

1103

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
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Financial Crimes Enforcement Network

Subject Alternative Name (4D) Record
This record contains information related to the subject’s alternative name. A maximum of 99 4D
records may be associated with a Subject (4A) Record. Do not include a 4D record if no
alternative names are known. The 4D record item number corresponds to the FinCEN SAR Part
I, Item 6.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4D."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-157

Part I Alternate Name
(Item 6)

150

Enter the subject's alternate name, e.g. AKA for an individual
or DBA for an entity). Do not include the acronyms “AKA” or
“DBA” with the alternative name. Left justify and space-fill this
entry.

158-1190

Filler

1033

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
40

Financial Crimes Enforcement Network

Subject Telephone Number (4E) Record
This record contains information related to the subject’s telephone number A maximum of 99 4E
records may be associated with a Subject (4A) Record. Do not include a 4E record if no
telephone number is known. The 4E record item numbers correspond to the FinCEN SAR Part I,
Items 17-18.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4E."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

Part I Phone Number
- Type (Item 17)

Enter the code from the list below that describes the type of the
subject’s telephone number. Space-fill if the telephone type is
unknown.
Code
Description
A
Home
B
Work
C
Mobile
D
Fax

9-24

Part I Phone Number
(Item 18)

Enter the subject's telephone number as a single string without
formatting such as hyphens, spaces, or parenthesis. Left justify
and space-fill this entry.

25-30

Part I Phone Number
Extension (Item 18)

Enter the subject's telephone extension number. Left justify and
space-fill this entry. Otherwise space-fill this field.

31-1190

Filler

1160

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
41

Financial Crimes Enforcement Network

Subject E-mail Address (4F) Record
This record contains information related to the subject’s e-mail address. A maximum of 99 4F
records may be associated with a Subject (4A) Record. Do not include a 4F record if no e-mail
address is known. The 4F record item number corresponds to the FinCEN SAR Part I, Item 19.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4F."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-57

E-mail Address
(Item 19)

Enter the subject's e-mail address. Include all formatting,
punctuation, and special characters in the e-mail address. Left
justify and space-fill this entry.

58-1190

Filler

1133

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
42

Financial Crimes Enforcement Network

Subject Website (URL) Address (4G) Record
This record contains information related to the subject’s website (URL) address. A maximum of
99 4G records may be associated with a Subject (4A) Record. Do not include a 4G record if no
website (URL) address is known. The 4G record item number corresponds to the FinCEN SAR
Part I, Item 19.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4G."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-524

Website (URL)
Address (Item 19)

517

Enter the subject's website Uniform Resource Locator (URL)
address. Include all punctuation and special characters present
in the URL. Left justify and space-fill this entry.

525-1190

Filler

666

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
43

Financial Crimes Enforcement Network

Subject Relationship to Institution (4H) Record
This record contains information related to the subject’s relationship to the institution(s) listed
in Part III (Item 55) or Part IV (Item 80). A maximum of 99 4H records may be associated with a
Subject (4A) Record. Do not include a 4H record if the subject has no relationship to a financial
institution recorded in the Part III or Part IV of the FinCEN SAR. The 4H record item numbers
refer to the FinCEN SAR Part I, items 21-23.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4H."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-32

Institution TIN (Item
21)

Enter the Taxpayer Identification Number (TIN) of the
institution listed in Part III (Item 55) or Part IV (Item 80) which
has a relationship with the subject. Left justify and space-fill
this entry. Space-fill if the TIN is unknown.

33-44

Relationship of the
Subject to an
Institution (Item 21)

Enter the code(s) from the list below that describe the subject's
relationship to the institution (enter all that apply). Left justify
and space-fill this entry. Do not include spaces between
multiple entries.
Code
Description
B
Accountant
C
Agent
D
Appraiser
E
Attorney
F
Borrower
G
Customer
H
Director
I
Employee
J
No relationship to institution
K
Officer
L
Owner or Controlling Shareholder
Z
Other

45-94

Relationship of the
Subject to an
Institution - Other
Description (Item 21)

REQUIRED (conditional). If the relationship code is "Z,”
provide a brief description of the relationship. Left justify and
space-fill this entry. Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
44

Financial Crimes Enforcement Network

Field
Position(s)

Field Name

Length

Description and Remarks

Status of Subject
Relationship to
Institution (Item 22)

Enter the code from the list below that describes the status of
the relationship between the subject and the institution if a
relationship identified in Item 21 is “H,” “I,” “K,” or “L.”
Space-fill if the relationship identified in Item 21 is not “H,” “I,”
“K,” or “L.”
Code
Description
A
Relationship continues
B
Terminated
C
Suspended/Barred
D
Resigned

96-103

Action Date (Item 23)

Enter the action date if the status of the relationship was "B,"
"C," or "D." Record the date as a numeric 8-position entry in the
format MMDDCCYY where MM = month, DD = day, CC =
century, and YY = year. This entry cannot be greater than Date
Filed (Item 98) in the 3A record. Space-fill if the “Status of
Subject Relationship to Institution” is "A" or space filled.

104-1190

Filler

1087

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
45

Financial Crimes Enforcement Network

Affected TIN & Account Number (4I) Record
This record contains information related to the financial institution(s) and/or account number(s)
related to the subject. A maximum of 99 4I records may be associated with a Subject (4A)
Record. NOTE: Each 4I record can hold only one financial institution TIN and one account
number. If more than one account number is associated with the financial institution TIN
identified in this record, the TIN must be recorded in a separate 4I record along with the
additional account number for the TIN. If one or more account numbers are related to the
subject, but the financial institution TIN is unknown, space-fill the TIN and enter a account
number in as many 4I records as necessary to record all known account numbers. Conversely, if
one or more TINs are related to the subject, but the account number is unknown, enter a
financial institution TIN and space-fill the account number in as many 4I records as necessary to
record all known TINs where account numbers are unknown. Do not include a 4I record if no
account numbers are involved in the suspicious activity or if both the financial institution TIN
and the account number are unknown. The 4I record item number refers to the FinCEN SAR
Part I, Item 24.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "4I."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

Non-US Financial
Institution (Item 24)

Enter “X” if the account is located at a non-US financial
institution. Otherwise space-fill this field.

9-33

Financial Institution
TIN and Account
Number Related to
Subject (Item 24)

Enter the Taxpayer Identification Number (TIN) of the financial
institution holding the account related to the subject. Left
justify and space-fill the entry. Space-fill if the TIN is unknown
and the account number is known.

34-73

Financial Institution
TIN and Account
Number Related to
Subject (Item 24)

Enter the account number of the financial institution account
that is related to the subject. Left justify and space-fill the entry.
Space-fill if the account number is unknown but the financial
institution TIN is known.

Account Closed - Yes
(Item 24)

Enter "X" if the account is closed. Otherwise space-fill this field.

75-1190

Filler

1116

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
46

Financial Crimes Enforcement Network

Narrative Description (5A) Record – Required
This record contains a detailed description of the suspicious activity. There can be more than
one of this record type, but no more than 20 of these records for the same Suspicious Activity
(3A) Record. NO CARRIAGE RETURNS ARE ALLOWED IN THE RECORD. The 5A record
item number refers to the FinCEN SAR Part V.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "5A."

3-7

Transaction Sequence
Number

REQUIRED. Enter the Transaction Sequence Number from the
associate suspicious activity (3A) record.

8-857

Suspicious Activity
Information Narrative

850

REQUIRED. Enter a detailed description of the suspicious
activity. Left justify and space-fill this entry.

858-1190

Filler

333

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill this field.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
47

Financial Crimes Enforcement Network

Suspicious Activity Information Summary (9A) Record –
Required
There must be one of this record type for each Suspicious Activity Information (3A) Record on
the file. This record contains counts of the number of suspicious activity record types associated
with each FinCEN SAR reported.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "9A."

3-9

Suspicious Activity
Count (3A)

REQUIRED. Enter “0000001” in this field.

10-16

Subject Count (4A)

REQUIRED. Enter the number of Subject (4A) Records for the
Financial Institution(s). Right justify and zero-fill this entry.

17-23

Narrative Description
(5A) Count

REQUIRED. Enter the number of Narrative Description (5A)
Records for the Financial Institution(s). Right justify and zerofill this entry.

24-30

Branch Office
Information (2C)
Count

REQUIRED. Enter the number of Branch Office Information
(2C) Records for the Financial Institution(s). Right justify and
zero-fill this entry.

31-1190

Filler

1160

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
48

Financial Crimes Enforcement Network

Filing Institution Summary (9B) Record – Required
There must be one of this record type for each Filing Institution Information (2A) Record on the
file. This record contains counts of the number of 2B, 2C, 3A, 4A, and 5A record types
associated with the Filing Institution Information (2A) Record.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "9B."

3-9

Financial Institution
Where Activity
Occurred Count (2B)

REQUIRED. Enter the number of Financial Institution Where
Activity Occurred (2B) Records for the Filing Institution.

10-16

Suspicious Activity
Count (3A)

REQUIRED. Enter the number of Suspicious Activity
Information (3A) Records for the Filing Institution. Right justify
and zero-fill this entry.

17-23

Subject Count (4A)

REQUIRED. Enter the number of Subject (4A) Records for the
Filing Institution. Right justify and zero-fill this entry.

24-30

Narrative Description
(5A) Count

REQUIRED. Enter the number of Narrative Description (5A)
Records for the Filing Institution. Right justify and zero-fill this
entry.

31-37

Branch Office
Information (2C)
Count

REQUIRED. Enter the number of Branch Office Information
(2C) Records for the Filing Institution. Right justify and zero-fill
this entry.

38-1190

Filler

1153

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

Electronic Filing Requirements for the FinCEN Suspicious Activity Report (FinCEN SAR)
49

Financial Crimes Enforcement Network

File Summary (9Z) Record – Required
There should only be one of these records on the file and it must be the very last record on the
file. The record contains counts of the number of the various record types which are on the file.
The File Summary (9Z) Record should contain the following data elements:

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

REQUIRED. Enter "9Z."

3-9

Filing Institution
Contact Information
Count (2A)

REQUIRED. Enter the number of Filing Institution Information
(2A) Records. Right justify and zero-fill this entry.

10-16

Financial Institution
Where Activity
Occurred Count (2B)

REQUIRED. Enter the number of Financial Institution Where
Activity Occurred (2B) Records. Right justify and zero-fill this
entry.

17-23

Suspicious Activity
Count (3A)

REQUIRED. Enter the number of Suspicious Activity
Information (3A) Records. Right justify and zero-fill this entry.

24-30

Subject Count (4A)

REQUIRED. Enter the number of Subject (4A) Records. Right
justify and zero-fill this entry.

31-37

Narrative Description
(5A) Count

REQUIRED. Enter the number of Narrative Description (5A)
Records. Right justify and zero-fill this entry.

38-44

Branch Office
Information (2C)
Count

REQUIRED. Enter the number of Branch Office Information
(2C) Records. Right justify and zero-fill this entry.

45-51

Attachment Count

REQUIRED. Enter the number of Attachments. Right justify
and zero-fill. Right justify and zero-fill this entry.

52-1190

Filler

1139

Space-filled.

1191-1200

User Field

Use this field for any descriptive information you may require;
Otherwise space-fill.

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Acknowledgement Record Formats
The FinCEN SAR batch acknowledgement file defined below is provided in ASCII format. The
acknowledgement file will contain a corresponding acknowledgement record for each record
received on the batch file (NOTE: the narrative record will not have a corresponding
acknowledgement record.).

Acknowledgement Transmitter (1A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
transmitter data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 1A record.

3-10

Coverage Beginning
Date

Field Position 508-515 of the incoming 1A record. Enter as a
numeric 8-position field in the format: month, day, century,
year (MMDDCCYY)

11-18

Coverage Ending Date

Field Position 516-523 of the incoming 1A record. Enter as a
numeric 8-position field in the format: month, day, century,
year (MMDDCCYY)

19-26

Transmitter Control
Code (TCC)

Field Position 524-531 of the incoming 1A record.

27-29

Batch Sequence
Number (BSN)

References the batch number of the original transmission file
(532-534, 1A Record). This number is for BSA E-Filing internal
use only.

30-119

Error Codes

Please see Attachment A - Error Code List for a detailed
description of each error code. Error codes associated with this
record begin with a “T,” are 3 alphanumeric characters in
length, and are left-justified. Unused error code positions are
zero filled.

120-129

User Field

Field Positions 1191-1200 of the incoming 1A record.

130-150

Filler

Space-filled.

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Acknowledgement Filing Institution Information (2A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Filing Institution Information (2A) Record data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 2A record.

3-27

Filing Institution TIN

Field Position 155-179 of the incoming 2A record. Unused field
positions are space-filled.

28-117

Error Codes

Please see Attachment A - Error Code List for a detailed
description of each error code. Error codes associated with this
record are 4 alphanumeric characters in length and are leftjustified. Unused error code positions are zero filled.

118-127

User Field

Field Positions 1041-1050 of the incoming 2A record.

128-150

Filler

Space-filled.

Acknowledgement Financial Institution Where Activity Occurred
(2B) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Financial Institution Where Activity Occurred (2B) Record data received by FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 2B record.

3-12

Financial Institution
Location Code

Field Position 3-12 of the incoming 2B record.

13-102

Error Codes

103-112

User Field

Field Positions 1041-1050 of the incoming 2B record.

113-150

Filler

Space-filled.

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Acknowledgement Branch or Office Where Activity Occurred (2C)
Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Branch or Office Where Activity Occurred (2C) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 2C record.

3-12

Branch or Office
Location Code

Field Position 3-12 of the incoming 2C record.

13-102

Error Codes

103-112

User Field

Field Positions 1191-1200 of the incoming 2C record.

113-150

Filler

Space-filled.

Acknowledgement Suspicious Activity (3A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Suspicious Activity (3A) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3A record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3A record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 3A record.

122-150

Filler

Space-filled.

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Acknowledgement Commodity Type (3B) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Commodity Type (3B) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3B record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3B record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

Filler

Field Positions 1041-1050 of the incoming 3B record.

122-150

Filler

Space-filled.

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Acknowledgement Product/Instrument Description (3C) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Product/Instrument Description (3C) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3C record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3C record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 3C record.

122-150

Filler

Space-filled.

Acknowledgement Market Where Traded (3D) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Market Where Traded (3D) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3D record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3D record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 3D record.

122-150

Filler

Space-filled.

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Acknowledgement IP Address (3E) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the IP
Address (3E) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3E record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3E record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 3E record.

122-150

Filler

Space-filled.

Acknowledgement CUSIP Number (3F) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
CUSIP Number (3F) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 3F record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 3F record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 3F record.

122-150

Filler

Space-filled.

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Acknowledgement Subject (4A) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Subject (4A) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4A record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4A record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4A record.

122-150

Filler

Space-filled.

Acknowledgement Address (4B) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Address (4B) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4B record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4B record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4B record.

122-150

Filler

Space-filled.

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Acknowledgement Identification (4C) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Identification (4C) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4C record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4C record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4C record.

122-150

Filler

Space-filled.

Acknowledgement Alternative Name (4D) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Alternative Name (4D) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4D record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4D record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4D record.

122-150

Filler

Space-filled.

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Acknowledgement Telephone (4E) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Telephone (4E) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4E record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4E record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4E record.

122-150

Filler

Space-filled.

Acknowledgement E-mail Address (4F) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the Email Address (4F) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4F record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4F record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4F record.

122-150

Filler

Space-filled.

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Acknowledgement Website (URL) Address (4G) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Website (URL) Address (4G) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4G record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4G record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4G record.

122-150

Filler

Space-filled.

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Acknowledgement Relationship to Institution (4H) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Relationship to Institution (4H) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4H record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4H record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4H record.

122-150

Filler

Space-filled.

Acknowledgement Affected TIN & Account Number (4I) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record contains identifying information and error codes pertaining to the
Affected Account Number (4I) Record data received by FinCEN.
Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 4I record.

3-7

Transaction Sequence
Number

Field Position 3-7 of the incoming 4I record.

8-21

BSA Identifier

Assigned by FinCEN. A unique identifying number.

22-111

Error Codes

112-121

User Field

Field Positions 1041-1050 of the incoming 4I record.

122-150

Filler

Space-filled.

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Acknowledgement Trailer for Transmitter (9Z) Record
This record is created by FinCEN as part of an acknowledgement file returned to the
transmitter. This record is a systems control record and it summarizes the data processed by
FinCEN.

Field
Position(s)

Field Name

Length

Description and Remarks

1-2

Record Type

Field Position 1-2 of the incoming 9Z record.

3-12

Number of Filing
Institution Contact
Information (2A)
Records in File

Generated by FinCEN.

13-22

Number of Suspicious
Activity (3A) Records
in File

Generated by FinCEN.

23-112

Error Codes

Please see Attachment A - Error Code List for a detailed
description of each error code. Error codes associated with this
record are 3 alphanumeric characters in length and are leftjustified. Unused error code positions are zero filled.

112-121

User Field

Field Positions 1041-1050 of the incoming 9Z record.

122-150

Filler

Space-filled.

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Attachment A – Error Code List
Error
Code

Error Description

Record

Field
Position

Report
Field
Number

Fatal Errors
*A fatal error will result in a rejection of the batch file (not including error code F24).
F02

Number of records reported does not match the computer
count for the 2A record.

F03

Number of records reported does not match the computer
count for the 2B record.

F04

Number of records reported does not match the computer
count for the 3A record in the file.

F09

Number of records reported does not match the computer
count for the 4A records.

F10

Number of records reported does not match the computer
count for the 5A records.

F11

A required 2A record is missing from the submitted file.

F12

A required 2B record is missing from the submitted file.

F13

A required 3A record is missing from the submitted file.

F14

A required 4A record is missing from the submitted file.

F15

A required 5A record is missing from the submitted file.

F16

A required 1A record is missing from the submitted file.

F17

A required 9A record is missing from the submitted file.

F18

A required 9Z record is missing from the submitted file.

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Error
Code

Error Description

F21

A required 9B record is missing from the submitted file.

F24

Number of forms reported on the batch form does not
match the computed count of the forms found in the file.

F34

An invalid record type was present in Field Position 1-2 in
one or more records of the submitted file.

F37

A duplicate “Transaction Sequence”/”Transaction
Sequence Number” was present on the submitted file.

F38

The “Transaction Sequence”/”Transaction Sequence
Number” is missing from the submitted file.

F39

A non-numeric “Transaction Sequence”/”Transaction
Sequence Number” is present in the submitted file.

F87

A problem was encountered while processing the
attachment(s) that has resulted in the rejection of your
submission. Please ensure you are following the correct
procedures regarding the size, filename, and format of
attachments or contact the BSA E-Filing Help Desk for
assistance.

F88

The Transmitter Control Code (TCC) specified in the file is
not a valid production TCC.

F89

The submitted batch contains an invalid format indicator
in the 1A record.

F93

An invalid line terminator was present on the submitted
file

F94

Cannot continue processing the submitted file because of
previous errors encountered.

F96

One, or more, invalid characters were present in the
submitted file.

F97

An invalid record sequencing was present on the
submitted file.

F98

An invalid record length was present on the submitted file.

Record

Field
Position

Report
Field
Number

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Error
Code

Error Description

Record

F99

Unknown file error. Please contact the BSA E-Filing Help
Desk for assistance.

Field
Position

Report
Field
Number

Validation Errors
*Validation errors are for informational purposes only.
E00

This submission has been rejected because it contains
significant errors. Please fix and re-submit the file.

E02

This submission has been accepted and will be processed
by FinCEN, however it contains some errors which need to
be corrected once this submission has been acknowledged.
File Errors
*File error codes containing an asterisk (*) are primary errors that must be corrected.

T01

Transmitter name is blank.

3-152

T02

Transmitter address is blank.

153-252

T03

Transmitter city is blank.

253-302

T04

Transmitter state is blank.

303-305

T05

Transmitter ZIP Code or foreign postal code is blank.

306-314

T06

Transmitter telephone number is blank.

317-332

T07

Transmitter contact name is blank.

333-482

T08

Transmitter TIN is blank.

483-507

T09

Coverage beginning date is blank or invalid.

508-515

T10

Coverage ending date is blank or invalid.

516-523

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

T12

The Transmitter Control Code is blank.

524-531

S201*

Filing institution primary federal regulator is blank.

3-4

S202*

Filing institution primary federal regulator contains an
invalid code.

3-4

S203*

Filing institution name is blank.

5-154

S204*

Filing institution TIN is blank.

155-179

S205*

Filing institution TIN is an invalid number string such as
all zeros, all nines, 123456789, or a U.S. TIN and not nine
digits.

155-179

S206

Filing institution TIN type is blank.

180

S207

Filing institution TIN type contains an invalid code.

180

S208

Filing institution type is blank.

181

S209

Filing institution type contains an invalid code.

181

S210

Filing institution type other description is blank.

182-231

82z

S211

Filing institution type for Securities/Futures contains an
invalid code.

232-244

S212

Filing institution type for Securities/Futures other
description is blank.

245-294

83z

S213

Filing institution identification type contains an invalid
code.

295

S214

Filing institution identification number is blank.

296-315

84f

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S215

Filing institution street address is blank.

316-415

S216

Filing institution city is blank.

416-465

S217

Filing institution state is not a valid state code and filing
institution country is equal to CA, MX, or US.

466-468

S218

Filing institution state is blank and the filing institution
country is equal to CA, MX, or US.

466-468

S219

Filing institution ZIP Code or foreign postal code is blank.

469-477

S220

Filing institution ZIP Code is a nine digit code ending in
four zeros/nines and the filing institution country is equal
to US.

469-477

S221

Filing institution ZIP Code is not equal to five or nine
digits or contains non-numeric values and the filing
institution country is equal to US.

469-477

S222

Filing institution country is blank.

478-479

S223

Filing institution country is not a valid country code.

478-479

S224

Financial institution type is blank.

S225

Financial institution type contains an invalid code.

S226

Financial institution type other description is blank.

14-63

47z

S227*

Financial institution primary federal regulator is blank.

64-65

S228*

Financial institution primary federal regulator contains an
invalid code.

64-65

S229

Gaming institution type contains an invalid code.

66-69

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S230

Gaming institution type other description is blank.

70-119

49z

S231

Securities/Futures institution type contains an invalid code.

120-129

S232

Securities/Futures institution type other description is
blank.

130-179

50z

S233

Financial institution identification type contains an invalid
code.

180

S234

Financial institution identification number is blank.

181-200

51f

S235

The financial institution’s role in the transaction contains
an invalid code.

201

S236*

Financial institution legal name is blank.

202-351

S237*

Financial institution TIN is blank.

503-527

S238*

Financial institution TIN is an invalid number string such
as all zeros, all nines, 123456789, or a U.S. TIN and not nine
digits.

503-527

S239

Financial institution TIN type is blank.

529

S240

Financial institution TIN type contains an invalid code.

529

S241

Financial institution street address is blank.

530-629

S242

Financial institution city is blank.

631-680

S243

Financial institution state is not a valid state code.

682-684

S244

Financial institution state is blank and financial institution
country is equal to CA, MX, or US.

682-684

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S245

Financial institution ZIP Code or foreign postal code is
blank.

685-693

S246

Financial institution ZIP Code is a nine digit code ending
in four zeros/nines and financial institution country is
equal to US.

685-693

S247

Financial institution ZIP Code is not equal to five or nine
digits or contains non-numeric values, and financial
institution country is equal to US.

685-693

S248

Financial institution country is blank.

695-696

S249

Financial institution country is not a valid country code.

695-696

S250

The loss reported for the financial institution contains nonnumeric values or is in an invalid format.

718-732

S251

The branch/office’s role in the transaction contains an
invalid code.

S252

Branch/office street address is blank.

14-113

S256

Branch/office ZIP Code is a nine digit code ending in four
zeros or four nines and branch/office country is US.

167-175

S257

Branch/office ZIP Code is not equal to five or nine digits, or
contains non-numeric values and branch/office country is
US.

167-175

S258

Branch/office country is blank and Part III No Branch
Activity (Item 65) is blank.

176-177

S259

Branch/office country is not a valid country code.

176-177

S301

Filing type is blank.

S302

Filing type contains an invalid code.

S303*

The amount involved in the suspicious activity report is
blank.

26-40

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S304*

The amount involved in the suspicious activity report
contains non-numeric values or is in an invalid format.

26-40

S305

The amount involved in the suspicious activity report is
greater than the cumulative amount reported.

26-40

S306*

The date or beginning date of the suspicious activity is
blank.

42-49

27a

S307

The date or beginning date of the suspicious activity is
greater than the date filed.

42-49

27a

S308

The date or beginning date of the suspicious activity is not
greater than or equal to January 1, 1950.

42-49

27a

S309*

The date or beginning date of the suspicious activity is not
a numeric 8-position field in MMDDCCYY format where
MM=month, DD=day, CC=century, YY=year.

42-49

27a

S310

The ending date of the suspicious activity is greater than
the date filed.

50-57

27b

S311

The ending date of the suspicious activity is not a numeric
8-position field in MMDDCCYY format where
MM=month, DD=day, CC=century, YY=year.

50-57

27b

S312

The cumulative amount of the suspicious activity is blank
when the report is a continuing report and an amount has
been recorded in the amount involved.

58-72

S313

The cumulative amount of the suspicious activity contains
non-numeric values or is in an invalid format.

58-72

S315

The suspicious activity "Structuring" contains one or more
invalid codes.

73-79

S316

The suspicious activity "Structuring" other description is
blank.

80-129

29z

S317

The suspicious activity "Terrorist Financing" contains one
or more invalid codes.

130-131

S318

The suspicious activity "Terrorist Financing" other
description is blank.

132-181

30z

S319

The suspicious activity "Fraud" contains one or more
invalid codes.

182-192

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S320

The suspicious activity "Fraud" other description is blank.

193-242

31z

S321

The suspicious activity "Casinos" contains one or more
invalid codes.

243-247

S322

The suspicious activity "Casinos" other description is
blank.

248-297

32z

S323

The suspicious activity "Money laundering" contains one
or more invalid codes.

398-310

S324

The suspicious activity "Money laundering" other
description is blank.

311-360

33z

S325

The suspicious activity "Identification/Documentation"
contains one or more invalid codes.

361-366

S326

The suspicious activity "Identification/Documentation"
other description is blank.

367-416

34z

S327

The suspicious activity "Other suspicious activity" contains
one or more invalid codes.

417-435

S328

The suspicious activity "Other suspicious activity" other
description is blank.

436-485

35z

S329

The suspicious activity "Insurance" contains one or more
invalid codes.

486-492

S330

The suspicious activity "Insurance" other description is
blank.

493-542

36z

S331

The suspicious activity "Securities/Futures/Options"
contains one or more invalid codes.

543-547

S332

The suspicious activity "Securities/Futures/Options" other
description is blank.

548-597

37z

S333

The suspicious activity "Mortgage Fraud" contains one or
more invalid codes.

598-602

S334

The suspicious activity "Mortgage Fraud" other description
is blank.

603-652

38z

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S335*

The suspicious activity type for items 29 through 38 is
blank when at least one item must contain an alpha
character entry.

73-652

29a-38z

S336

The product type(s) involved in the suspicious activity
contains one or more invalid codes.

653-672

S337

The product type(s) involved in the suspicious activity
other description is blank.

673-722

39z

S338

The instrument type(s)/payment mechanism(s) involved in
the suspicious activity contains one or more invalid codes.

723-732

S339

The instrument type(s)/payment mechanism(s) involved in
the suspicious activity other description is blank.

733-782

40z

S340

Law Enforcement telephone number contains non-numeric
values or is in an invalid format.

1083-1098

S341

Law Enforcement contact date is not a numeric 8-position
field in MMDDCCYY format where MM=month, DD=day,
CC=century, YY=year.

1105-1112

S342

Law Enforcement contact date is greater than date filed.

1105-1112

S343

Designated contact office is blank.

1113-1122

S344

Designated contact telephone number is blank.

1123-1138

S345

Designated contact telephone number contains nonnumeric values or is in an invalid format.

1121-1136

S346

Date filed is blank.

1145-1152

S347

Date filed is not a numeric 8-position field in MMDDCCYY
format where MM=month, DD=day, CC=century, YY=year.

1145-1152

S348

Date filed is greater than the current date or is less than the
date transmitted.

1145-1152

S401

Subject "if entity" contains an invalid code.

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S402

Subject "all critical subject information unavailable"
contains an invalid code.

S403*

Subject last/legal name is blank.

10-159

S404

Subject first name is blank.

161-195

S405

Subject gender contains an invalid code.

267

S406

Subject street address is blank.

8-107

S407

Subject city is blank.

109-158

S408

Subject state is not a valid state code and subject country is
equal to CA, MX, or US.

160-162

S409

Subject state is blank and subject country is equal to CA,
MX, or US.

160-162

S410

Subject ZIP Code or foreign postal code is blank.

164-172

S411

Subject ZIP Code is a nine digit code ending in four
zeros/nines and subject country is equal to US.

164-172

S412

Subject ZIP Code is not equal to five or nine digits or
contains non-numeric values, and subject country is equal
to US.

164-172

S413

Subject country is blank.

174-175

S414

Subject country is not a valid country code.

174-175

S415*

Subject TIN is blank.

304-328

S416

Subject TIN is an invalid number string such as all zeros,
all nines, 123456789, or a U.S. TIN and not nine digits.

304-328

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S417

Subject TIN type is blank.

330

S418

Subject TIN type contains an invalid code.

330

S419*

Subject identification is blank.

8-87

S420

Subject identification type contains an invalid code.

S421

Subject identification other description is blank.

38-87

S422

Subject identification issuing state is not a valid state code
and subject country is equal to CA, MX, or US.

33-35

15f

S423

Subject identification issuing country is not a valid country
code.

36-37

15g

S424

Subject date of birth is blank.

322-339

S425

Subject date of birth is less than January 1, 1900.

322-339

S426

Subject date of birth contains non-numeric values or is in
an invalid format.

322-339

S427

Subject telephone type contains an invalid code.

S428

Subject telephone number is blank and subject telephone
type contains an entry.

9-24

S429

Subject telephone number contains non-numeric values or
is in an invalid format.

9-24

S430

Subject e-mail address is in an invalid format.

8-57

S431

Subject Website URL is in an invalid format.

8-524

S432

Subject corroborative statement to filer contains an invalid
code.

341

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Error
Code

Error Description

Record

Field
Position

Report
Field
Number

S434

The type of relationship of the subject to the institution
listed in Part III or Part IV contains an invalid code.

33-44

S435

The relationship of the subject to the institution listed in
Part III or Part IV other description is blank.

45-94

21z

S436

The status of the subject's relationship to the institution
listed in Part III or Part IV contains an invalid code.

S437

The action date related to the status of the subject's
relationship to the institution listed in Part III or Part IV is
blank and Item 22b, 22c, or 22d is checked.

96-103

S438

The action date related to the status of the subject's
relationship to the institution listed in Part III or Part IV
contains non-numeric values or is in an invalid format.

96-103

S439

The action date related to the status of the subject's
relationship to the institution listed in Part III or Part IV is
greater than the date filed.

96-103

S501*

The Narrative Description contains one or more blank
records.

8-857

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Attachment B – Error Correction Instructions
This attachment identifies the requirements and procedures for correcting FinCEN SAR errors
reported to batch filers during the FinCEN SAR acknowledgement process.
Error Categories:
There are two types of errors identified in batch files: format errors that may result in automatic
rejection of a batch file and file errors that represent errors in data entered in individual fields.
Fatal format errors prevent the batch file from being processed. For example, error F18 “A
required 9Z record is missing from the submitted file” is a fatal error because each batch file
must contain a 9Z record. Error S224 “Financial institution type is blank” is a file error because
it indicates data is missing from a record.
File errors are classified as primary or secondary errors, depending on their importance.
Primary errors are file errors that violate electronic filing requirements or instructions and so
degrade FinCEN SAR data quality that they must be corrected. Primary errors make it difficult
for regulators, analysts, and law enforcement investigators to locate the FinCEN SARs in the
database or identify the nature and circumstances of the suspicious activity. Examples of such
errors include blank last names or legal names, missing financial institution Employer
Identification Numbers, or an invalid entry in the suspicious activity date field. Attachment A –
Error Code List identifies primary errors by adding an asterisk (*) to the four digit error code.
Secondary errors are file errors that violate electronic filing requirements or instructions but
have a lesser impact on FinCEN SAR data quality. Examples of secondary errors are ZIP Codes
that end in four zeros (e.g. 123450000), missing dates of birth, or invalid telephone numbers.
Correction Requirements:
Filers should immediately correct and resubmit a batch file rejected for fatal errors when
notified by FinCEN the batch file was not accepted. Rejection of a batch file does not relieve the
filer of the responsibility to file a FinCEN SAR within the time frames established by the BSA.
When a batch file is accepted by the BSA E-Filing Program, filers receive an acknowledgement
file that records all errors identified in the batch file. A FinCEN SAR that contains primary
errors must be re-filed as a corrected report with the primary errors and any secondary errors
corrected. FinCEN SARs that contain only secondary errors need not be corrected. FinCEN
requires that filers prevent all reported errors in their future filings.
FinCEN recommends that primary error corrections be made no later than 30 days after
receiving error notifications. Furthermore, FinCEN recommends that filers remedy any systemic
problems in their electronic submissions within 30 days of receiving error notifications. If
technical issues prevent filers from implementing corrections within these time frames, filers
should notify FinCEN by writing to:

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Financial Crimes Enforcement Network
Office of Compliance
P.O. Box 39
Vienna, VA 22183
This correspondence should explain the technical issues that prevent meeting this time frame,
provide an estimate of when the issues will be resolved, and include a contact name and
telephone number.
Correction Procedures:
A FinCEN SAR batch file is rejected when it contains fatal format errors. The filer must correct
all errors identified in the batch file and resubmit the batch file to BSA E-Filing. Because they
were not accepted by FinCEN, all FinCEN SARs in the re-submitted batch file must retain their
original Type of Filing. Do not identify FinCEN SARs in a re-filed batch file as corrected reports
unless they originally were filed as corrected reports in the rejected batch file.
If errors in an accepted batch file involve primary file errors, filers must file corrected reports on
all FinCEN SARs containing primary file errors using the following procedures:










Make the corrections to both the primary and secondary errors in all FinCEN SARs that
contains primary errors. Filers are encouraged, but not required, to correct any
secondary errors in FinCEN SARs that contained no primary errors.
Enter “B” at Field Position 9 “Type of Filing” in the Suspicious Activity Information (3A)
Record for each corrected FinCEN SAR.
Enter the prior report’s BSA Identifier from the FinCEN SAR acknowledgement file at
Field Position 12-25 “Prior Report Document Control/File Number” in the Suspicious
Activity Information (3A) Record for each corrected FinCEN SAR.
Ensure that Field Position 1145-1152 contains a new “Date Filed” in the Suspicious
Activity Information (3A) Record for each corrected FinCEN SAR.
Complete all other data in the FinCEN SARs in their entirety.
Record the nature of all corrections at the beginning of the initial Narrative Description
(5A) Record for each corrected FinCEN SAR.
Retransmit the corrected FinCEN SARs in a new batch file. Do not re-transmit the
original batch file because this will cause duplicate database entries on any FinCEN
SARs that were not corrected.

FinCEN monitors FinCEN SAR filings to identify financial institutions that fail to correct
primary errors in prior filings or to prevent previously-reported errors of any type in future
filings. FinCEN may report such failures to a financial institution’s primary federal/state
regulator or BSA examiner.

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Attachment C – Electronic Filing Instructions
Safe Harbor: Federal law (31 U.S.C. 5318(g)(3)) provides financial institutions complete
protection from civil liability for all reports of suspicious transactions made to appropriate
authorities, including supporting documentation, regardless of whether such reports are filed
pursuant to a regulatory requirement or on a voluntary basis. Specifically, the law provides that
a financial institution, and its directors, officers, employees, and agents, that make a disclosure
of any possible violation of law or regulation, including in connection with the preparation of
suspicious activity reports, “shall not be liable to any person under any law or regulation of the
United States, any constitution, law, or regulation of any State or political subdivision of any
State, or under any contract or other legally enforceable agreement (including any arbitration
agreement), for such disclosure or for any failure to provide notice of such disclosure to the
person who is the subject of such disclosure or any other person identified in the disclosure.”
Confidentiality of SARs:
A FinCEN Suspicious Activity Report (FinCEN SAR), and any information that would reveal
the existence of the FinCEN SAR (collectively, “SAR information”), are confidential, and may
not be disclosed except as specified in 31 U.S.C. 5318(g)(2) and in FinCEN’s regulations (31 CFR
Chapter X).
SAR Sharing:
FinCEN has concluded that a depository institution that has filed a SAR may share the SAR, or
any information that would reveal the existence of the SAR, with an affiliate, as defined in
FinCEN Guidance FIN-2010-G006 issued January 3, 2011, provided the affiliate is subject to a
SAR regulation. The sharing of SARs with such affiliates facilitates the identification of
suspicious transactions taking place through the depository institution’s affiliates that are
subject to a SAR rule. Therefore, such sharing within the depository institution’s corporate
organizational structure is consistent with the purposes of Title II of the BSA.
Prohibition on Disclosures by Financial Institutions:
Federal law (31 U.S.C. 5318(g)(2)) provides that a financial institution, and its directors, officers,
employees, and agents who, pursuant to any statutory or regulatory authority or on a voluntary
basis, report suspicious transactions to the government, may not notify any person involved in
the transaction that the transaction has been reported. Provided that no person involved in the
suspicious activity is notified, 31 CFR Chapter X clarifies that the following activity does not
constitute a prohibited disclosure:


Disclosure of SAR information to certain governmental authorities or other examining
authorities that are otherwise entitled by law to receive SAR information or to examine
for or investigate suspicious activity;

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


Disclosure of the underlying facts, transactions, and documents upon which a FinCEN
SAR is based; and
For those institutions regulated by a Federal functional regulator (Federal bank
regulatory agencies, the Securities and Exchange Commission (SEC), and the
Commodity Futures Trading Commission (CFTC)), the sharing of SAR information
within an institution’s corporate organizational structure, for purposes that are
consistent with the Bank Secrecy Act, as determined by regulation or guidance.

Prohibition on Disclosures by Government Authorities:
Federal law (31 U.S.C. 5318(g)(2)) also provides that an officer or employee of any Federal, state,
local, tribal, or territorial government within the United States who has knowledge that such
report was made, may not disclose to any person involved in the transaction that the
transaction has been reported, other than as necessary to fulfill the official duties of such officer
of employee. FinCEN’s regulations clarify that “official duties” must be consistent with Title II
of the Bank Secrecy Act and shall not include the disclosure of a SAR, or any information that
would reveal the existence of a SAR, in response to a request for disclosure of non-public
information or a request for use in a private legal proceeding, including a request pursuant to
31 CFR § 1.11.
FinCEN SAR Filing Instructions:
1. Who Must File: Certain financial intuitions operating in the United States shall file with
FinCEN, to the extent and in the manner required by 31 CFR Chapter X and 12 CFR §§ 21.11,
163.180, 208.62, 353.3, and 748.1, a report of any suspicious transaction relevant to a possible
violation of law or regulation. The following financial institutions are required to file a FinCEN
SAR: Banks (31 CFR §1020.320) including Bank and Financial Holding Companies (12 CFR §
225.4); Casinos and Card Clubs (31 CFR § 1021.320); Money Services Businesses (31 CFR §
1022.320); Brokers or Dealers in Securities (31 CFR § 1023.320); Mutual Funds (31 CFR §
1024.320); Insurance Companies (31 CFR § 1025.320); Futures Commission Merchants and
Introducing Brokers in Commodities (31 CFR § 1026.320); and Residential Mortgage Lenders
and Originators (31 CFR § 1029.320).
2. Filing Deadlines: A FinCEN SAR shall be filed no later than 30 calendar days after the date
of the initial detection by the reporting financial institution of facts that may constitute a basis
for filing a report. If no suspect is identified on the date of such initial detection, a financial
institution may delay filing a FinCEN SAR for an additional 30 calendar days to identify a
suspect, but in no case shall reporting be delayed more than 60 calendar days after the date of
such initial detection. In situations involving violations that require immediate attention, such
as terrorist financing or ongoing money laundering schemes, the financial institution shall
immediately notify by telephone an appropriate law enforcement authority in addition to filing
timely a FinCEN SAR. Financial institutions wishing voluntarily to report suspicious

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transactions that may relate to terrorist activity may call FinCEN’s Financial Institutions Hotline
at 1-866-556-3974 in addition to filing timely a FinCEN SAR.
3. Filing Requirements for Financial Institutions: A financial institution must report any
transaction that requires reporting under the terms of 31 CFR Chapter X if the transaction is
conducted or attempted by, at, or through the financial institution and involves or aggregates at
least $5,000 ($2,000 for money services businesses, except as provided in Section 6 of this
document) and the financial institution knows, suspects, or has reason to suspect that the
transaction or pattern of transactions of which the transaction is a part:


Involves funds derived from illegal activity or is intended or conducted in order to hide
or disguise funds or assets derived from illegal activity (including, without limitation,
the ownership, nature, source, location, or control of such funds or assets) as part of a
plan to violate or evade any Federal law or regulation or to avoid any transaction
reporting requirement under Federal law or regulation;



Is designed, whether through structuring or other means, to evade any requirement of
31 CFR Chapter X or any other regulation promulgated under the Bank Secrecy Act,
Public Law 91-508, as amended, codified at 12 U.S.C 1829b, 12 U.S.C. 1951-1959, and 31
U.S.C. 5311-5332;



Has no business or apparent lawful purpose or is not the sort in which the particular
customer would normally be expected to engage, and the financial institution knows of
no reasonable explanation for the transaction after examining the available facts,
including the background and possible purpose of the transaction, or



Involves the use of the financial institution to facilitate criminal activity.

4. Additional Filing Instructions for Banks: In addition to the above requirements, a bank (as
defined in 31 CFR § 1010.100) must file a FinCEN SAR for activity (as required by 31 CFR §
1020.320 and 12 CFR §§ 21.11, 163.180, 208.62, 353.3, and 748.1) involving:


Insider abuse involving any amount. Whenever the bank detects any known or
suspected Federal criminal violations, or pattern of criminal violations, committed or
attempted against the financial institution or involving a transaction or transactions
conducted through the financial institution, where the bank believes that it was either an
actual or potential victim of a criminal violation, or series of criminal violations, or that
the bank was used to facilitate a criminal transaction, and the bank has a substantial
basis for identifying one of its directors, officers, employees, agents or other institutionaffiliated parties as having committed or aided in the commission of a criminal act
regardless of the amount involved in the violation.

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

Violations aggregating $5,000 or more where a suspect can be identified. Whenever
the bank detects any known or suspected Federal criminal violation, or pattern of
criminal violations, committed or attempted against the bank or involving a transaction
or transactions conducted through the bank and involving or aggregating $5,000 or
more in funds or other assets, where the bank believes that it was either an actual or
potential victim of a criminal violation, or series of criminal violations, or that the bank
was used to facilitate a criminal transaction, and the bank has a substantial basis for
identifying a possible suspect or group of suspects. If it is determined prior to filing this
report that the identified suspect or group of suspects has used an “alias,” then
information regarding the true identity of the suspect or group of suspects, as well as
alias identifiers, such as drivers’ licenses or social security numbers, addresses and
telephone numbers, must be reported.



Violations aggregating $25,000 or more regardless of a potential suspect. Whenever the
bank detects any known or suspected Federal criminal violation, or pattern of criminal
violations, committed or attempted against the bank or involving a transaction or
transactions conducted through the bank and involving or aggregating $25,000 or more
in funds or other assets, where the bank believes that it was either an actual or potential
victim of a criminal violation, or series of criminal violations, or that the bank was used
to facilitate a criminal transaction, even though there is no substantial basis for
identifying a possible suspect or group of suspects.

5. Voluntary FinCEN SAR Filings: Financial institutions may also file with FinCEN a report of
any suspicious transaction that it believes is relevant to the possible violation of any law or
regulation but whose reporting is not required by 31 CFR Chapter X. A voluntary filing does
not relieve a financial institution from the responsibility of complying with any other reporting
requirements imposed by the SEC, the CFTC, a self-regulatory organization (SRO) (as defined
in section 3(a)(26) of the Securities Exchange Act of 1934, 15 U.S.C. 78c (a)(26)), or any
Registered Futures Association (RFA) or Registered Entity (RE) (as these terms are defined in
the Commodity Exchange Act, 7 U.S.C. 21 and 7 U.S.C. 1a(29)).
6. Exceptions: The following are exceptions to the FinCEN SAR reporting requirements:


A bank, casino, broker or dealer in securities (BD), futures commission merchant (FCM),
or introducing broker in commodities (IB-C) is not required to file a FinCEN SAR for a
robbery or burglary committed or attempted against the financial institution when the
robbery or burglary is reported to appropriate law enforcement authorities.



A FinCEN SAR is not required to be filed for lost, missing, counterfeit, or stolen
securities that are reported pursuant to the requirements of 17 CFR § 240.17f-1.



A BD is not required to file a FinCEN SAR on violations of any of the Federal securities
laws or the rules of a SRO by the BD or any of its officers, directors, employees or other

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registered representatives, other than a violation of 17 CFR § 240.17a-8 or 17 CFR § 405.4,
so long as such violation is appropriately reported to the SEC or an SRO.


An FCM or an IB-C, or any of its officers, directors, employees or associated persons, is
not required to file a FinCEN SAR for a violation of the Commodity Exchange Act (7
U.S.C. 1 et seq.), the regulations of the CFTC (17 CFR Chapter 1), or the rules of any RFA
or RE (as those terms are defined in the Commodity Exchange Act, 7 U.S.C. 21 and 7
U.S.C. 1a(29)), as long as such violation is appropriately reported to the CFTC, an RFA,
or RE. This exception does not apply to violations of 17 CFR § 42.2.



An insurance company is not required to report the submission to it of false or
fraudulent information to obtain a policy or make a claim, unless the company has
reason to believe that that the false or fraudulent submission relates to money
laundering or terrorist financing.



An issuer of money orders or traveler’s checks is not required to report a transaction or
pattern of transactions when the transactions were identified through a review of
clearance records or other similar records and the transaction amount or aggregated
transaction amount involves funds or other assets of less than $5,000.

7. Additional Reporting: The Bank Secrecy Act requires financial institutions to file a Currency
Transaction Report (CTR) in accordance with the Department of the Treasury’s implementing
regulations (31 CFR § 1010.310) whenever a currency transaction exceeds $10,000. If a currency
transaction exceeds $10,000 and is otherwise reportable as suspicious activity, the institution
must file both a CTR (reporting the currency transaction) and a FinCEN SAR (reporting the
suspicious activity). If a currency transaction is $10,000 or less and is otherwise reportable as a
suspicious activity, the institution should only file a FinCEN SAR. Appropriate records must be
maintained in each case. Residential Mortgage Lenders and Originators are required to file
Form 8300, Report of Cash Payments Over $10,000 Received in a Trade or Business, instead of a
CTR.
FinCEN SAR Electronic Filing Instructions
General Instructions:
1. Filing Reports: This report should be E-filed through the Financial Crime Enforcement
Network (FinCEN) BSA E-Filing System. Go to http://bsaefiling.fincen.treas.gov to register if
not already registered. Financial institutions that file reports individually will use FinCEN’s
discrete FinCEN Suspicious Activity Report (FinCEN SAR) to file their reports. Financial
institutions that use batch filing or system-to-system filing to transmit multiple reports must
transmit files that conform to the requirements of FinCEN’s “General Specifications for
Electronic Filing of Bank Secrecy Act (BSA) Reports” (General Specifications) and “FinCEN
Suspicious Activity Report (FinCEN SAR) Electronic Filing Requirements.”
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2. Recording Information: Complete each FinCEN SAR by providing as much information as
possible. Although all items should be completed fully and accurately, items marked with an
asterisk (*) must be completed even when the required data are unknown. Filers must follow
the electronic filing instructions for these items by providing the required data or, if instructions
permit, by checking the box “Unknown” to indicate that the required data was unknown. Items
that do not begin with an asterisk must be completed if the data are known and will be left
blank if the data are unknown. If an item’s instructions differ from this general instruction, the
item instructions must be followed. These instructions supersede all prior SAR instructions and
FinCEN guidance on use of special responses in SAR items when the data are unknown or not
available in an electronic filing. Therefore, the use of special responses such as “UNKNOWN,”
“NONE,” “NOT APPLICABLE,” or “XX” and their variants is prohibited in the FinCEN SAR.
NOTE: Throughout these instructions the phrase “check box” and similar wording is used to
denote checking an appropriate box in certain data items on the discrete FinCEN SAR. This is
deemed equivalent to instructions in the Electronic Filing Requirements to enter appropriate
codes in the same data items in transmission files. For example, the requirement to check box 1
“Initial report” in the discrete FinCEN SAR is the equivalent of entering code “A” in “Type of
Filing” in the Electronic Filing Requirements Suspicious Activity Information (3A) Record. In
some discrete FinCEN SAR data items check boxes have been replaced by drop-down lists.
NOTE: Throughout these instructions there are requirements to complete items multiple times
in a discrete FinCEN SAR if the filer has multiple entries for that item. This is deemed
equivalent to completing multiple records for that item in the Electronic Filing Requirements.
For example, these instructions direct filers to complete multiple Item 6 “Alternate name” fields
if the filer has knowledge of multiple alternate names for a subject. This is equivalent to a batch
filer completing multiple Subject Alternative Name (4D) Records for the same subject.
3. Corrected/Amended Reports: A corrected report on a previously-filed FinCEN SAR or prior
SAR versions must be filed whenever errors are discovered in the data reported in that FinCEN
SAR. An amended report must be filed on a previously-filed FinCEN SAR or prior SAR
versions whenever new data about a reported suspicious activity is discovered and
circumstances will not justify filing a continuing report (see General Instruction 4). Both
corrected and amended reports must be completed in their entirety, with the necessary
corrections or amendments made to the data. In both cases box 1b “Correct/Amend prior
report” must be checked. If known, the prior report’s Document Control Number (DCN) or BSA
Identifier (BSA ID) must be entered in field 1e. If the prior report’s DCN or BSA ID is unknown,
field 1e should be zero-filled. All corrections or amendments must be described completely at
the beginning of the Part V Suspicious Activity Information – Narrative section. If a FinCEN
SAR is filed to correct or amend a prior SAR version, the FinCEN SAR must be completed in its
entirety. This includes FinCEN SAR items that apply to the suspicious activity but were not
present on the prior SAR version. FinCEN SAR items not on the prior SAR version need not be

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described in the narrative. BSA IDs, which replaced DCNs, are provided in acknowledgement
records sent to member financial institutions by the BSA E-Filing System.
4. Continuing Reports: A continuing report should be filed on suspicious activity that
continues after an initial FinCEN SAR is filed. Continuing reports should be filed at least every
90 days until the suspicious activity ceases. Continuing reports must be completed in their
entirety, including the information about all subjects involved in the suspicious activity and all
financial institutions where the activity occurred. The continuing report Part V narrative should
include all details of the suspicious activity for the 90-day period encompassed by the report,
and only such data from prior reports as is necessary to understand the activity. Do not
reproduce the narratives from prior reports in the continuing report. Provide both the dollar
amount involved in the suspicious activity for the 90-day period in Item 26 and the cumulative
dollar amount for the current and all prior related reports in Item 28. If continuing losses are
involved for any financial institution recorded in Part III, record the 90-day loss in Item 63 and
the cumulative loss in Part V.
5. Joint Report: A FinCEN SAR may be jointly filed when two or more distinct financial
institutions collaborate in filing a single FinCEN SAR on suspicious activity involving all of the
collaborating financial institutions. Financial institutions are “distinct” for this purpose when
they are different legal entities; a financial institution is not distinct from its own branches. Joint
filing of a single FinCEN SAR is prohibited when any of the Part I “Subject Information”
subjects of the would-be jointly filed FinCEN SAR have a box in Item 21 checked that identifies
the subject as a director, employee, officer, or owner/controlling shareholder of the filing
institution or a would-be joint filer. In that case separate FinCEN SARs must be filed by each
institution. To be a jointly-filed FinCEN SAR, box 1d “Joint report” must be checked. In
addition, the filing institution listed in Part IV “Filing Institution Contact Information” must
identify in Part V “Suspicious Activity Information – Narrative” which Part III “Information
about Financial Institution Where Activity Occurred” institutions are joint filers. The filing
institution must include joint filer contact information in Part V, along with a description of the
information provided by each joint filer. Record joint filer information in Part III Items 47
through 63 and joint filer branch information in Part III Items 64 through 77. Filing a joint
FinCEN SAR does not relieve joint filers of the responsibility to report information about the
suspicious activity that was not included in the joint filing. A filing institution cannot designate
another institution as a joint filer unless the designated joint filer is aware of and approves the
FinCEN SAR filing in its entirety. A filer that designates another institution as a joint filer
without gaining that institution’s agreement to the joint filing and approval of the contents of
the joint filing may have committed a willful violation of the Bank Secrecy Act, if the improper
designation leads to the disclosure of the SAR filing to a person not entitled to information
about the filing. Both filers and joint filers are required to keep copies of the FinCEN SAR and
their own supporting documentation for five (5) years after the date of filing.
6. Supporting Documentation: Filers can include a single Microsoft Excel compatible comma
separated values (CSV) file with no more than one megabyte of data as an attachment to the
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FinCEN SAR. The contents of this file must be described in Part V. This file would be most
suitable for documenting transaction records that are too numerous to record in Part V. Do not
include any other supporting documentation with the FinCEN SAR. Instead, describe in Part V
other supporting documentation not included in the file. Filers must retain all supporting
documentation or a business record equivalent for five (5) years from the date of the report (31
CFR § 1010.430). All supporting documentation (such as copies of instruments; receipts; sale,
transaction or clearing records; photographs; and surveillance audio or video recordings) must
be made available to appropriate authorities upon request. See Attachment D for information
on attaching comma separated (.CSV) files to a FinCEN SAR filing.
7. Addresses: For addresses in the U.S., Canada, or Mexico enter the permanent street address,
city, two or three letter state/territory/province code, ZIP Code or foreign postal code, and two
letter country code for the individual or entity recorded in Part I, Part III, or Part IV. Provide the
apartment number or suite number, if known, following the street address. A non-location
address such as a post office box or rural route number should be used only if no other street
address information is available. ZIP Codes must be five or nine digits. ZIP Codes and foreign
postal codes must be entered without formatting or special characters such as spaces or
hyphens. For example, the ZIP Code 12354-6120 would be entered as 123546120. The foreign
postal code HKW 702 would be entered HKW702. For other foreign addresses enter the street
address, city, postal code, and two letter country code or address equivalent. If a foreign
address contains other address information that does not conform to the FinCEN SAR address
format, record equivalent address information in the FinCEN SAR address items and the full
address in Part V. Complete any address item that is known, even if the complete address is
unknown. No abbreviations are permitted in city names, which must be completely spelled out.
A U.S. city name must match the city name used by the U.S. Postal Service for the associated
state and ZIP Code. For U.S. address use only the authorized U.S. Postal Service state, territory,
or military address abbreviations found at https://www.usps.com/ship/officialabbreviations.htm. For Canadian provinces and territories use the Canada Post Corporation
codes found at http://www.canadapost.ca/tools/pg/manual/PGaddress-e.asp#1380608. For
Mexican states and territories use the ISO 3166-2 three-letter codes found at
http://www.commondatahub.com/live/geography/state_province_region/iso_3166_2_state_code
s. For all countries use the ISO 3166-1 two-letter country codes found at
http://www.iso.org/iso/country_names_and_code_elements.
8. Telephone Numbers: Record all telephone numbers, both foreign and domestic, as a single
number string without formatting or special characters such as parentheses or hyphens. For
example, a number in the format (NNN) NNN-NNNN would be recorded as
NNNNNNNNNN. Indicate the type of telephone number provided (home, work, mobile, or
fax) by checking the appropriate box. Provide the telephone extension number if known.
Telephone numbers that are part of the North American Numbering Plan used by the U.S.,
Canada, many Caribbean countries, and current/former U.S. Pacific island protectorates must
consist of an area code and seven-digit telephone number. Other foreign telephone numbers
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should include the country number code. If only a partial telephone number is known record
that number in the phone number item and explain in Part V that the entry is a partial number.
9. Identifying Numbers: Enter all identifying numbers as a single text string without
formatting or special characters such as hyphens or periods. An identifying number in the
format NNN-NN-NNNN would be entered as NNNNNNNNN. Such numbers include account
numbers, alien registration numbers, CRD, CUSIP®, driver’s license numbers, state
identifications, EINs, IARDs ITINs, passport numbers, RSSDs, SEC IDs, and SSNs.
10. Monetary Amounts: Record all monetary amounts in U.S. Dollars rounded up to the next
whole dollar. The amount $5,265.25 would be recorded as $5,266. If the amount involves a
foreign currency, record the currency name, amount, and country of origin in Part V. When
converting a foreign currency to U.S. Dollars use an exchange rate for the date or dates the
foreign currency was involved in the suspicious activity.
11. Prohibited Words and Phrases: Do not use the following words or variations of these words
in text fields, other than in Part V:

a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.

AKA
COMPUTER GENERATED
CUSTOMER
DBA
NON CUSTOMER
NONE
NOT APPLICABLE
OTHER
SAME
SAME AS ABOVE
SEE ABOVE
SEE NARRATIVE
SIGNATURE CARD
T/A
UNKNOWN
VARIOUS
XX

12. Name Editing Instructions: Because many names do not consist of a single first name,
middle name, and last name, care must be taken to ensure these names are entered properly in
the BSA SAR. This is especially important when there are separate fields for the last name, first
name, and middle name. Some names have multiple surnames (family names) or multiple given
names that do not include a middle name. Others may not be written in [first name] [middle
name] [last name] order. Multiple surnames must be entered in the last name field. For
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example, Hispanic names may be written in the order of given name, father's last name, and
mother's last name, e.g., “Juan Vega Santiago.” Thus the surname “VEGA SANTIAGO” would
be entered in the last name field with “JUAN” entered in the first name field. Some Hispanic
surnames consist of three names (e.g., father’s last name, mother’s last name, and husband’s
father’s last name in the case of a married woman). In that case all three would be entered in a
last name field. Hispanic names do not have middle names, so a multiple Hispanic given name
such as “Rosa Maria” would be recorded in the first name field. In some cultures names consist
of multiple first names and a single family name, not necessarily in (first name) (last name)
order. For example, the Korean name “Kim, Chun Nam” consists of the family name “Kim” and
the first name “Chun Nam” separated by a comma and space. There is no middle name. In this
case “KIM” would be entered in the last name field and “CHUN NAM” would be entered in
the first name field. Nothing is entered in the middle name field. When an individual name is
entered in a single name field it should be entered in [first name] [middle name] [last name]
order regardless of any foreign naming conventions. Thus, “Kim, Chun Nam” would be entered
as “CHUN NAM KIM” in a single name field. Punctuation and special characters should be
used in names only when they are part of the name. For example, the period in “Expedia.Com”
should be included because it is part of the name. Placing a period after a middle initial would
be prohibited because the period is not part of the middle name. Abbreviations in names are
prohibited unless an abbreviation is part of a legal name. Entry of middle initials is permitted
when a middle name is unknown. A name suffix may be abbreviated, i.e. Junior can be JR,
Senior can be SR, the Third can be III, etc.
Item Instructions
NOTE: Critical fields are identified with the * symbol in front of the data element number.
-------------------------------------------------- Type of Filing --------------------------------------------* 1. Check all that apply:
a. Initial report
b. Correct/Amend prior report
c. Continuing activity report
d. Joint report
e. Prior report Document Control Number/BSA Identifier if items 1b or 1c are checked
Item *1 Type of Filing: Check box 1a "Initial report" if this is the first report filed on the
suspicious activity. FinCEN SARs filed as a result of a historical or other review of past
transactional activity, either directed by a regulating authority or conducted as a financial
institution initiative, must always be initial reports. Check box 1b "Correct/Amend prior report"
if the report corrects or amends a previously-filed report. Check box 1c "Continuing activity
report" if this report involves suspicious activity reported on one or more previous reports.
Continuing reports should be filed at least every 90 days on continuing suspicious activity. If
this report is being jointly filed with another financial institution, check the appropriate box 1a,
1b, or 1c and box 1d "Joint report." Filers must clearly identify in Part V which Part III financial
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institutions are the joint filers on the FinCEN SAR. If box 1b or 1c is checked, enter in field 1e
the Document Control Number (DCN) or the BSA Identifier (BSA ID) assigned to the previous
SAR by FinCEN. If the DCN or BSA ID is unknown, enter zeros in place of the unknown
number. See General Instructions 3 through 5 for additional information on Type of Filing.
-------------------------------------------- Part I: Subject Information --------------------------------------Part I Subject Information: Complete a Part I section on each known subject involved in the
suspicious activity. Persons who are victims of the suspicious activity are not subjects and
should not be recorded in a Part I section. Victim information, if necessary for a complete
description of the suspicious activity, should be recorded in Part V. If the subject is or all
subjects are unknown, complete a single Part I record with box 2b checked to show that all
subject information was unavailable for critical Items 3, 4, 8, 9, 10, 11, 12, 13, 15, and 16. These
critical items (denoted with an asterisk “*”) except Item 24 must be blank. Record the nature of
the unknown subject(s) in Part V. If the suspicious activity involves known and unknown
subjects, complete a Part I section on each known subject and record the nature of the unknown
subject(s) in Part V. Do not complete Part I records on the unknown subjects when there are
known subjects.
2. Check:
a. if entity
b. if all critical* subject information is unavailable (does not include item 24)
Item 2a Check if entity: Check box 2a if the person described in Part I is an entity and not an
individual.
Item 2b Check if all critical subject information is unavailable: Check box 2b if the information
in Part I is unavailable for all critical subject items except Item 24. These critical items (3, 4, 8, 9,
10, 11, 12, 13, 15, and 16) and their associated “Unknown” fields must be left blank.
* 3. Individual’s last name or entity’s legal name
a. (check if) unknown
Item *3 Individual's last name or entity's legal name: Enter the individual's last name or the
entity's legal name. The legal name is the name on the articles of incorporation or other
document that established the entity. Do not abbreviate names unless an abbreviation is part of
the legal name. Item 3 and box 3 “Unknown” must be blank if box 2b is checked. Leave item 3
blank and check box 3 “Unknown” if the individual's last name or the entity's legal name is
unknown and box 2b is not checked.
* 4. First name
a. (check if) unknown

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Item *4 First name: Enter the individual's first name. If the first name is unknown leave item 4
blank and check box 4 “Unknown.” Leave Item 4 and box 4 “Unknown” blank if box 2a or 2b is
checked.
5. Middle name/initial
Item 5 Middle name/initial: Enter the individual's middle name or initial. Leave this item blank
if the middle name or initial is unknown or box 2a is checked.
5. Suffix name
Item 5 Suffix name: Enter the individual’s suffix such as JR, SR, III, etc. Leave this item blank if
the suffix is unknown or the individual’s legal name does not include a suffix.
5. Gender
a. (Check if) Male
b. (Check if) Female
c. (Check if) Unknown
Item 5 Gender: Select options 5a Male or 5b Female if individual’s gender is known. Select
option 5c “Unknown” if the individual’s gender is unknown. Leave Item 5 blank if the subject is
an entity. Item 5 (Gender) does not create an obligation for a financial institution to collect this
data when such collection would be in conflict with the financial institution’s obligations under
any other federal law.
6. Alternate name, e.g. AKA - Individual or DBA - Entity
Item 6 Alternate name: Enter the individual's also known as (AKA) name or the entity's doing
business as (DBA) name if different from the name entered in Items 3-5. Do not include the
acronyms AKA or DBA with the name. Multiple Item 6 fields may be completed if multiple
subject alternate names are known.
7. Occupation or type of business
a. NAICS Code
Item 7 Occupation or type of business: Record the occupation, profession, or type of business of
the individual or entity recorded in Part I. Use specific descriptions such as doctor, carpenter,
attorney, used car dealership, plumber, truck driver, hardware store, etc. Do not use nondescriptive items such as businessman, merchant, retailer, retired, or self-employed. If words
like self-employed, unemployed, or retired are used, add the current or former profession if
known (e.g. self-employed building contractor, retired teacher, or unemployed carpenter). If the
occupation or business activity can be described in more detail, include the additional
information in Part V.
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Item 7a NAICS Code: Select from the FinCEN-approved list the North American Industry
Classification System (NAICS) code for the occupation or type of business entered in Item 7.
Access the NAICS Code list from the BSA E-Filing Web Site
(http://bsaefiling.fincen.treas.gov/main.html).
* 8. Address
a. (check if) unknown
Items *8 - *12 Subject address items: Enter the subject's permanent street address, city, two or
three letter state/territory/province code (U.S./Canada/Mexico only), ZIP Code or foreign postal
code, and two letter country code. Complete any address item that is known, even if the
complete address is unknown. If an address item is unknown, leave that item blank and check
box 8 "Unknown." If box 2b is checked all address items and check boxes must be blank. See
General Instruction 7 for additional information on entering addresses. Multiple sets of address
fields may be completed if multiple present and past subject addresses are known.
* 9. City
a. (check if) unknown
* 10. State
a. (check if) unknown
* 11. ZIP/Postal Code
a. (check if) unknown
* 12. Country Code
a. (check if) unknown
* 13. TIN (enter number in space provided and check appropriate type below)
a. (check if) unknown
Item *13 TIN: Enter the subject's U.S. taxpayer identification number (TIN) or foreign equivalent
without formatting or punctuation. If the number is unknown, check box 13 "Unknown" and
leave Item 13 blank. Leave item 13 and box 13 “Unknown” blank if box 2b is checked. See
General Instruction 9 for information on entering identifying numbers.
14. TIN type
a. EIN
b. SSN-ITIN
c. Foreign

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Item 14 TIN type: Identify the type of TIN recorded in Item 13. Select option 14a “EIN” if the
subject has a U.S. Employer Identification Number (EIN). Box 2a “If entity” must be checked
because an EIN is assigned only to an entity. Select option 14b“SSN-ITIN” if the subject has a
U.S. Social Security Number (SSN) or Individual Taxpayer Identification Number (ITIN). Select
option 14c “Foreign” if the subject has a foreign TIN of any type. Box 2a must be checked if the
foreign subject is an entity. If 14c is checked, record in Part V the name of the country that
issued the foreign TIN. Enter the subject’s TIN type if known even if the actual TIN is unknown
and Item 13 “Unknown” is checked. If a 9-digit TIN is entered in Item 13 but the TIN type is
unknown, select option 14a “EIN” if the subject is an entity and option 14b “SSN-ITIN” if the
subject is an individual. TINs that are not 9 digits are presumed to be foreign, so option 14c
“Foreign” would be selected.
* 15. Form of identification for subject:
a. (check if) Unknown
b. (check if) Driver’s license/state ID
c. (check if) Passport
d. (check if) Alien registration
e. Number
f. Issuing State
g. Issuing Country
z. (check if) Other (and specify type in space provided)
Item *15 Form of identification: Enter in Item 15 the information used to identify the individual
or entity. Select option 15b if the identification was a driver's license or state ID, 15c if the
identification was a passport or 15c if the identification was an alien registration. Select option
15z if a different identification was provided and describe that identification in the "Other" text
field. “Other” identification could include such things as an entity’s business license or
incorporation documents, corporate ID cards, local government ID cards, etc. Enter the
identification number in field 15e "Number." Do not include formatting such as hyphens or
periods. Select the appropriate state option in field 15f "Issuing state" if the identification issuer
was a U.S., Canadian, or Mexican state, territory, or province. Select the appropriate country
option in field 15f "Country" if the issuer was a country. If field 15f “Issuing state” contains an
entry, then 15g “Country” must contain “US,” “CA,” or “MX” as appropriate. See General
Instruction 7 for information about the codes to enter in state and country items. If the
identification issuer does not have a code, select the option for the issuer's country in field 15g.
For example, if the issuer was the London Police Department United Kingdom would be
selected in 15g. Record the name and nature of the issuer in Part V. Enter all identification data
that is available. Check box 15a “Unknown” only if all identification information is unknown
but the subject is known. Leave all fields in Item 15 blank if box 2b has been checked. Multiple
sets of Item 15 fields may be completed if multiple types of identification for a subject are
known. See General Instruction 9 for information on entering identifying numbers.
* 16. Date of birth
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a. (check if) unknown
Item *16 Date of birth: If the subject is an individual enter the subject's data of birth in Item 16.
Filers of FinCEN’s discrete FinCEN SAR must use the format MM/DD/CCYY where MM =
month, DD = day, CC = century, and YY = year. Batch filers must use the format MMDDCCYY.
If the birth day and or month is unknown, enter “00” for the unknown day or month. For
example, a date of birth with an unknown day in February 1978 would be entered as 02/00/1978
in a discrete FinCEN SAR and 02001978 in a batch filed FinCEN SAR. Do not enter zeros for the
year if the year is unknown. If the year of birth or the complete date of birth is unknown, check
box 16 "Unknown" and leave Item 16 blank. If box 2a or 2b is checked, Item 16 and box 16
“Unknown” must be blank.
17. Phone number – type
a. (check if) Home
b. (check if) Work
c. (check if) Mobile
d. (check if) Fax
Item 17 Phone number - type: Enter the type of telephone number recorded in Item 18 by
selecting the appropriate option. Leave Item 17 blank if no telephone number is recorded in
Item 18 or the type of telephone number is unknown. Multiple sets of Item 17 and Item 18 fields
may be completed if multiple telephone numbers for the subject are known.
18. Phone number
a. Extension (if any)
Item 18 Phone number: Enter the subject's U.S. or foreign telephone number with no formatting
such as parentheses, spaces, or hyphens. If the telephone number is unknown, leave item 18
blank. See General Instruction 8 for information on entering telephone numbers. Multiple sets
of Item 17 and Item 18 fields may be completed if multiple telephone numbers for the subject
are known.
Item 18a Ext. (if any): Enter the telephone extension associated with the subject's telephone
number. Leave Item 18a blank if there is no extension or the extension is unknown.
19. E-mail address (if available)
Item 19 E-mail address: Enter the subject's e-mail address if known. Include all formatting,
punctuation, and special characters in the e-mail address. Leave Item 19 blank if the e-mail
address is unknown. If additional e-mail addresses are known for a subject, complete additional
Item 19 fields. An e-mail address must contain the “@” sign and a period in the text following
the “@” sign. Examples: [email protected] or [email protected].

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19a. Website (URL) address (if available))
Item 19a Website (URL) address: Enter the subject's website URL (Uniform Resource Locator)
known. Include all punctuation and special characters present in the URL. If additional URLs
are known for a subject, complete an additional Item 19a for each URL. Leave Item 19a blank if
the URL is unknown.
20. Corroborative statement to filer?
a. (check if) Yes
b. (check if) No
Item 20 Corroborative statement: Select "Yes" if the subject has made a statement to the filer
admitting to involvement in or otherwise substantiating the suspicious activity. Record in Part
V the nature of the corroborative statement and how it was recorded, i.e. written confession,
verbal statement, etc. Select "No" if no corroborative statement was made to the filer.
21. Relationship of the subject to an institution listed in Part III or IV (check all that apply)
a. Institution TIN
b. Accountant
c. Agent
d. Appraiser
e. Attorney
f. Borrower
g. Customer
h. Director
i. Employee
j. No relationship to institution
k. Officer
l. Owner or Controlling Shareholder
z. Other (specify type in space provided)
Item 21 Relationship of the subject to an institution: If the subject has a relationship with a
financial institution or individual listed in Part III or Part IV, enter the financial institution's TIN
from Items 55 or 80 in field 21a "Institution EIN." Select all options 21b through 21l that
describe the relationship. If the relationship is not covered by any of options 21b through 21l,
select option 21z "Other" and enter a brief description of the relationship in the "Other" text
field. Avoid descriptions that are too general. For example, the entry "broker" should be made
more specific by indicating the relationship was "real estate broker," "securities broker," or
"mortgage broker." If necessary, describe the relationship more fully in Part V. If the subject has
no relationship with the financial institution, check box 21j "No relationship to institution." The
FinCEN SAR cannot be a joint FinCEN SAR if any of the options 21h “Director,” 21i
“Employee,” 21k “Officer,” or 21l “Owner or Controlling Shareholder” have been selected. If
the subject had a relationship with a financial institution recorded in Part III but the financial
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institution’s TIN was unknown, record the relationship but leave field 21a blank. If the subject
has relationships with multiple Part III and Part IV financial institutions, complete a separate set
of Item 21 fields for each financial institution. If more than one of 21h “Director,” 21i
“Employee,” 21k “Officer,” or 21l “Owner or Controlling Shareholder” is selected and/or the
status or action date is different for each, an Item 21 for each must be completed.
22. If item 21h, i, k, or l is selected, indicate status of relationship
a. (check if) Relationship continues
b. (check if) Terminated
c. (check if) Suspended/barred
d. (check if) Resigned
Item 22 If item 21h, i, k, or l is selected: If any of boxes 21h, 21i, 21k, or 21l are selected, select the
appropriate Item 22 option to indicate the status of the relationship. Select option 22a if the
relationship continues. Select option 22b if the subject was terminated, 22c if the subject was
suspended or barred, or 22d if the subject resigned. If multiple sets of Item 21 fields are
completed on a subject, complete an Item 22 field for each set.
23. Action date if 22 b, c, or d is checked
Item 23 Action date: If any of boxes 22b through 22d have been checked, enter the date the
action was taken. The date must be in MM/DD/YYYY format. Leave Item 23 blank if no action
was taken. If multiple Item 22 fields were created where box 22b, 22c, or 22d was checked,
complete an Item 23 for each Item 22.
* 24. Financial Institution TIN and account number(s) affected that are related to subject, if any.
a. (check if) No known account involved
b. (check if) Non-US Financial Institution
c. TIN
d. account number
e. (check if) closed
Item 24 Financial inst. EIN and acct. number(s) affected that are related to the subject, if any:
Enter in Item 24 information about any accounts involved in the suspicious activity that are
related to the subject recorded in Part I. Enter account numbers without formatting or special
characters such as spaces, hyphens, or periods. See General Instruction 9 for information about
entering account numbers in fields. An account is related to a subject if the subject owns the
account, has control over the account, or conducted activity in or through an account the subject
does not own or control. Check box 24a "No known acct. involved" if no account related to the
subject is involved in the suspicious activity. Check box 24b "Non-US Financial Institution" if
the account is located at a foreign financial institution. Enter in field 24c the TIN, if known, of
the financial institution where the account is held. If the TIN is unknown leave the TIN field
blank. Enter the account number involved in field 24d. If the account is closed, check the "Yes"
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box. If multiple account numbers are involved in the suspicious activity, complete an additional
set of account number fields for each account number. Record account numbers involved in the
suspicious activity that are related to the subject even if the TIN or name of the financial
institution is unknown. If the TIN of a financial institution associated with an account number
entered in 24d is unknown, record the institution name and associated account number in Part
V (example: “The account number 123654987 is held at First Federal Bank.”). If the filer is aware
that the subject has an account involved in the suspicious activity with a financial institution
listed in Part III but the account number is unknown, record the financial institution TIN in Item
24a but leave the associated account number field blank. Explain the missing account number in
Part V. The subject’s relationship to any account recorded in Item 24 must be clearly defined in
Part V unless the subject is the owner of the account (example: “The subject made unauthorized
purchases using a stolen debit card for account 3456789 owned by his aunt.”).
25. Subject’s role in suspicious activity (if applicable)
a. (check if) Purchaser/Sender
b. (check if) Payee/Receiver
c. (check if) Both a & b
Item 25 Subject's role: Record the subject's role in the suspicious activity by selecting the
appropriate option. Select option 25a "Purchaser/Sender" if the subject purchased or sent the
financial instrument(s) or product(s) involved in the suspicious activity. Select option 25b
"Payee/Receiver" if the subject was the payee or receiver of the instrument(s) or product(s).
Select option 25c "Both a & b" if the subject was both a purchaser/sender and payee/receiver.
Instruments and products are not limited to the instruments and products listed in Item 39 and
40.
-------------------------------------- Part II Suspicious Activity Information -----------------------------* 26. Amount involved in this report
a. (check if) Amount unknown
b. (check if) No amount involved
Item *26 Amount involved in this report: Enter the total dollar amount involved in the
suspicious activity for the time period of this report. If the amount is unknown, leave this item
blank and check box 26a "Amount unknown." Explain why the dollar amount is unknown in
Part V. If some dollar amounts are known while others are unknown, enter the total of all
known amounts and explain the unknown amounts in Part V. If there is no amount involved in
the suspicious activity, check box 26b “No amount involved.” If the FinCEN SAR is a
continuing report with box 1c "Continuing activity report" checked, enter only the amount
involved for the time period covered by this FinCEN SAR. Do not include amounts from prior
FinCEN SARs in Item 26. See General Instruction 10 for information on entering amounts.
* 27. Date or date range of suspicious activity for this report
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a. From: mm/dd/yyyy
b. To: mm/dd/yyyy
Item *27 Date or date range of suspicious activity for this report: Enter the suspicious activity
date or date range for this report. If the suspicious activity occurred on a single day, enter that
date in field 27a "From" and leave field 27b "To" blank. If the suspicious activity occurred on
multiple days, enter the earliest date of suspicious activity in field 27a and the most-recent date
of suspicious activity in field 27b. If the exact date(s) of the suspicious activity is (are) unknown,
enter a date range that the filer believes will encompass the date(s) of the suspicious activity.
Explain the nature of this date range in Part V. If the FinCEN SAR involves continuing activity
with box 1c "Continuing activity report" checked, enter only the date range covered by this
FinCEN SAR. Record in Part V the aggregated date range of all FinCEN SARs filed on the
continuing suspicious activity. Use the format MM/DD/CCYY for dates in a discrete FinCEN
SAR and the format MMDDCCYY for dates in a batch-filed FinCEN SAR.
28. Cumulative amount only if box 1c (continuing activity report) is checked
Item 28 Cumulative amount: Enter the cumulative amount involved in the suspicious activity in
Item 28 if box 1c "Continuing activity report" is checked. The cumulative amount represents the
total amount involved in all FinCEN SARs filed on the suspicious activity, including the current
FinCEN SAR. If box 1c is checked and the cumulative dollar amount is unknown because all
dollar amounts are unknown or no dollar amount is involved, enter zero (0) and explain the
entry in Part V. If some dollar amounts are known while others are unknown, enter the total of
all known amounts in Item 28 and explain the nature of the unknown amounts in Part V. See
General Instruction 10 for information on entering amounts. Leave Item 28 blank if box 1c is
not checked.
Items 29-38 Types of suspicious activity: Use the suspicious activity category Items 29 through
38 to record the type(s) of suspicious activity being reported. Check all boxes that apply to the
suspicious activity. If a category applies but none of the options apply, check the category’s box
“z Other” and briefly describe the type of suspicious activity in the associated text field. If
necessary, explain the type of suspicious activity in more detail in Part V.
29. Structuring
a. Alters transaction to avoid BSA recordkeeping requirement
b. Alters transaction to avoid CTR requirement
c. Customer cancels transaction to avoid BSA reporting and recordkeeping requirements
d. Multiple transactions below BSA recordkeeping threshold
e. Multiple transactions below CTR threshold
f. Suspicious inquiry by customer regarding BSA reporting or recordkeeping requirements
z. Other (specify type of suspicious activity in space provided)

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30. Terrorist Financing
a. Known or suspected terrorist / terrorist organization
z. Other (specify type of suspicious activity in space provided)
31. Fraud
a. ACH
b. Business loan
c. Check
d. Consumer loan
e. Credit/Debit card
f. Healthcare
g. Mail
h. Mass-marketing
i. Pyramid scheme
j. Wire
z. Other (specify type of suspicious activity in space provided)
32. Casinos
a. Inquiry about end of business day
b. Minimal gaming with large transactions
c. Suspicious intra-casino funds transfers
d. Suspicious use of counter checks or markers
z. Other (specify type of suspicious activity in space provided)
33. Money laundering
a. Exchanges small bills for large bills or vice versa
b. Suspicion concerning the physical condition of funds
c. Suspicion concerning the source of funds
d. Suspicious designation of beneficiaries, assignees or joint owners
e. Suspicious EFT/Wire transfers
f. Suspicious exchange of currencies
g. Suspicious receipt of government payments/benefits
h. Suspicious use of multiple accounts
i. Suspicious use of noncash monetary instruments
j. Suspicious use of third-party transactors (straw-man)
k. Trade Based Money Laundering / Black Market Peso Exchange
l. Transaction out of pattern for customer(s)
z. Other (specify type of suspicious activity in space provided)
34. Identification / Documentation
a. Changes spelling or arrangement of name
b. Multiple individuals with same or similar identities
c. Provided questionable or false documentation
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d. Refused or avoided request for documentation
e. Single individual with multiple identities
z. Other (specify type of suspicious activity in space provided)
35. Other suspicious activities
a. Account takeover
b. Bribery or gratuity
c. Counterfeit instruments
d. Elder financial exploitation
e. Embezzlement/theft/disappearance of funds
f. Forgeries
g. Identity theft
h. Little or no concern for product performance penalties, fees, or tax consequences
i. Misuse of “free look”/cooling off/right of rescission
j. Misuse of position or self-dealing
k. Suspected public/private corruption (domestic)
l. Suspected public/private corruption (foreign)
m. Suspicious use of informal value transfer system
n. Suspicious use of multiple transaction locations
o. Transaction with no apparent economic, business, or lawful purpose
p. Two or more individuals working together
q. Unauthorized electronic intrusion
r. Unlicensed or unregistered MSB
z. Other (specify type of suspicious activity in space provided)
36. Insurance
a. Excessive insurance
b. Excessive or unusual cash borrowing against policy/annuity
c. Proceeds sent to or received from unrelated third party
d. Suspicious life settlement sales insurance (e.g. STOLI’s, Viaticals)
e. Suspicious termination of policy or contract
f. Unclear or no insurable interest
z. Other (specify type of suspicious activity in space provided)
37. Securities / Futures / Options
a. Insider trading
b. Market manipulation/wash trading
c. Misappropriation
d. Unauthorized pooling
z. Other (specify type of suspicious activity in space provided)
38. Mortgage fraud
a. Appraisal fraud
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b. Foreclosure fraud
c. Loan modification fraud
d. Reverse mortgage fraud
z. Other
39. Were any of the following product type(s) involved in the suspicious activity? Check all that
apply:
a. Bonds/Notes
b. Commercial mortgage
c. Commercial paper
d. Credit card
e. Debit card
f. Forex transactions
g. Futures/Options on futures
h. Hedge fund
i. Home equity loan
j. Home equity line of credit
k. Insurance/Annuity products
l. Mutual fund
m. Options on securities
n. Penny stocks/Microcap securities
o. Prepaid access
p. Residential mortgage
q. Security futures products
r. Stocks
s. Swap, hybrid or other derivative
z. Other (specify type in space provided)
Item 39 Product types involved in suspicious activity: Check all Item 39 boxes that apply to
record the product type(s) involved in the suspicious activity. Option 39f ‘Forex transactions”
includes all foreign exchange transactions both on and off-exchange, including futures and
options on foreign exchange. Option 39g “Futures/Options on futures” includes futures and
options on any "commodity," as that term is defined in Section 1a(4) of the Commodity
Exchange Act, including broad-based security indexes. Option 39s “Swap, hybrid or other
derivative” includes all derivatives not included above including those traded over-the-counter
and off-exchange. If the product type is not covered by options 39a through 39s, check box 39z
"Other (list below)" and enter a brief description in the associated text field. If necessary provide
a more detailed product type (such as commodity futures contracts, options on commodity
futures contracts, commodity options, and OTC agricultural trade options) in Item 42
“Product/instrument description” or in Part V. If there are multiple product types not covered
by Item 39, record one in Item 39 "Other (List below)” and all others in Part V.

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40. Were any of the following instrument type(s)/payment mechanism(s) involved in the
suspicious activity? Check all that apply:
a. Bank/cashier’s check
b. Foreign currency
c. Funds transfer
d. Gaming instruments
e. Government payment
f. Money orders
g. Personal/Business check
h. Travelers checks
i. U.S. Currency
z. Other (specify type in space provided)
Item 40 Instrument types involved in suspicious activity: Check all Item 40 boxes that apply to
record the instrument type(s) involved in the suspicious activity. If the instrument type is not
covered by options 40a through 40i, check box 40z "Other (List below)" and enter a brief
description in the associated text field. If necessary provide a more-detailed description of the
instrument type in Part V. If there are multiple instrument types not covered by Item 40, record
one in Item 40 "Other (List below)” and all others in Part V.
41. Commodity type (if applicable)
Item 41 Commodity type: If a commodity is involved in the suspicious activity, record the
commodity type in Item 41. Multiple Item 41 fields should be completed if multiple commodity
types are involved in the suspicious activity.
42. Product/Instrument description (if needed)
Item 42 Product description: Provide a description of the product recorded in Item 39 or
instrument recorded in Item 40 if necessary for a more-complete understanding of the
suspicious activity. Multiple Item 42 fields should be completed if multiple products or
instruments requiring a description are involved in the suspicious activity.
43. Market where traded (list of codes will be provided – dropdown menu for electronic filers)
Item 43 Market where traded: Enter in Item 43 the three to five-letter code for the market where
a commodity recorded in Items 39 or 41 was traded. Multiple Item 43 fields should be
completed if multiple markets are involved in the suspicious activity. Use only the ISO 10383
Exchange/Market Identifier Codes (MIC) found at
http://www.iso15022.org/MIC/homepageMIC.htm.
44. IP Address (if available)

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Item 44 IP Address: Enter the Internet Protocol (IP) Address, if known, of a computer involved
in the suspicious activity. Enter as many IP addresses as are know up to a maximum of 99. If the
IP address is IPv4, use a variation of the format nnn.nnn.nnn.nnn (n = number) with periods
between the segments. If the IP address is IPv6, use a variation of the format
cccc:cccc:cccc:cccc:cccc:cccc:cccc:cccc (c = character, IPv6 is alphanumeric in some segments)
with colons between the segments. Left justify and space-fill the entry. Multiple Item 44 fields
should be completed if multiple IP addresses are involved in the suspicious activity.
45. CUSIP number
Item 45 CUSIP® number: Enter in Item 45 the CUSIP® (Committee on Uniform Securities
Identification Procedures) number of any securities products such as stocks and bonds involved
in the suspicious activity. Multiple Item 45 fields should be completed if there are multiple
CUSIP numbers for multiple securities products involved in the suspicious activity.
-------------- Part III Information about Financial Institution Where Activity Occurred -----------Part III records information about the financial institution(s) where the suspicious activity
occurred. Complete a separate Part III record on each financial institution involved in the
suspicious activity. If box 1d “Joint report” is checked there must be two or more Part III
records in the FinCEN SAR, one for the Part IV filing institution or filer subsidiary and one for
each joint filer. If a financial institution recorded in Part III has branches involved in the
suspicious activity, record the branch information in Items 64 through 70. Information on up to
99 branches can be recorded in a single SAR. A branch is a location (such as an office or ATM)
owned by the financial institution but located separately from the financial institution’s
headquarters. If a reporting financial institution has agents where the suspicious activity
occurred, a separate Part III must be prepared on each agent. An agent is an independent
financial institution (such as a supermarket that sells money orders or an independent
insurance agent) that has a contractual relationship with the reporting financial institution to
conduct financial transactions. Do not place agent information in branch fields. Generally, a
branch operates under the same TIN as the financial institution. An agent has a TIN different
from the financial institution. Financial institution as used in Part III includes individuals acting
as sole proprietorship financial institutions using their personal Social Security Number (SSN)
or Individual Taxpayer Identification Number (ITIN).
* 47. Type of financial institution (check only one)
a. Casino/Card club
b. Depository institution
c. Insurance company
d. MSB
e. Securities/Futures
f. Loan or Finance Company
g. Housing GSE
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z. Other (specify type of institution in space provided)
Item *47 - Type of financial institution: Select the appropriate type of financial institution that
best describes the financial institution recorded in Item 53. If none of those options apply, select
“Other” and enter a brief description in the associated text field. If necessary, include a moredetailed description in Part V.
NOTE: If the financial institution is a non-bank residential mortgage lender or originator, select
“Other” and enter “NON-BANK RESIDENTIAL MORTGAGE” in the associated text field. If
the financial institution is a dealer in precious metals, stones, or jewels, select option “Other”
and enter “DEALER IN PRECIOUS METALS STONES JEWELS” in the associated text field.
* 48. Primary Federal Regulator
a. Commodities Futures Trading Commission (CFTC)
b. Federal Reserve Board (FRB)
c. Federal Deposit Insurance Corporation (FDIC)
d. Internal Revenue Service (IRS)
e. National Credit Union Administration (NCUA)
f. Office of the Comptroller of the Currency (OCC)
g. Securities and Exchange Commission (SEC)
h. Federal Housing Finance Agency (FHFA)
z. Not Applicable.
Item *48 Primary federal regulator: Select the appropriate option to identify the primary federal
regulator or BSA examiner of the financial institution recorded in Part III. If more than one
regulator option could apply, enter the code for the regulator that has primary responsibility for
enforcing compliance with the BSA. If Item 47 option “Casino/Card Club,” “Insurance
Company,” or “MSB” was selected, the Item 48 entry must be “Internal Revenue Service (IRS).”
If the institution recorded in Part III is subject to U.S. law and none of the other codes apply,
select option “Internal Revenue Service (IRS).” If the institution recorded in Part III is not
subject to U.S. law, then select option “Not Applicable.”
49. If item 47a is checked indicate type (Check only one)
a. State licensed casino
b. Tribal authorized casino
c. Card club
z. Other (specify) (specify type in the space provided)
Item 49 Gaming institution type: If option 47a was selected indicating the financial institution is
a gaming institution such as a casino or card club, record the type of gaming institution by
checking the appropriate box. If none of the options 49a through 49c are appropriate, check box

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49z "Other" and provide a brief description in the associated text field. If necessary, include a
more detailed description in Part V.
50. If item 47e is checked, indicate type of Securities and Futures institution or individual where
activity occurred—check box(es) for functions that apply to this report
a. Clearing broker - securities
b. Futures Commission Merchant
c. Holding company
d. Introducing broker - commodities
e. Introducing broker - securities
f. Investment Adviser
g. Investment company
h. Retail foreign exchange dealer
i. Subsidiary of financial/bank holding company
z. Other (specify type of institution or individual in space provided)
Item 50 Securities and futures type: If option 47e was checked indicating the financial institution
is part of the securities and futures industries, check all boxes that apply to indicate the type of
securities and futures institution. If none of options 50a through 50i apply, check box 50z
"Other" and record a brief description of the type in the associated text field. Examples of this
are commodity pool operator or commodity trading adviser. If necessary, include a moredetailed description in Part V.
51. Financial institution identification number (Check one box to indicate type)
a. (check if) Central Registration Depository (CRD) number
b. (check if) Investment Adviser Registration Depository (IARD) number
c. (check if) National Futures Association (NFA) number
d. (check if) Research Statistics Supervision Discount (RSSD) number
e. (check if) Securities and Exchange Commission (SEC) number
f. (check if) National Association of Insurance Commissioners (NAIC Code)
g. (check if) Mortgage (NMLS ID)
h. Identification number
Item 51 Financial institution identification number: Select the appropriate option if the financial
institution recorded in Part III has a Central Registration Depository (CRD) number, an
Investment Adviser Registration Depository (IARD) number, a National Futures Association
(NFA) number, a Research Statistics Supervision Discount (RSSD) number, or a Securities and
Exchange Commission (SEC) Reporting File Number (RFN). Do not enter an SEC Central Index
Key (CIK) number in place of the RFN. Record the number in field 51h. See General Instruction
9 for information on entering identifying numbers.
52. Financial institution’s role in transaction (if applicable)
a. (check if) Selling location
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b. (check if) Paying location
c. (check if) Both a & b
Item 52 Financial institution role in transaction: Check the box “Selling location” if the customer
purchased at the Part III financial institution the products or instruments recorded in Items 39
or 40. Check the box “Paying location” if the customer received payment from the Part III
financial institution for the products or instruments recorded in Items 39 or 40. Check the box
“Both” if the Part III financial institution was both a paying and selling location for the products
or instruments recorded in Items 39 or 40.
* 53. Legal name of financial institution
a. (check if) unknown
Item 53 Legal name of financial institution: Enter the legal name of the financial institution as
recorded on articles of incorporation or other documents establishing the institution. Enter the
full name of the filer if the filer is an individual, such as a sole proprietorship, acting as a
financial institution. If an individual’s name is recorded, enter the name in (first name) (middle
name) (last name) or equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc. Check box
53 “Unknown” if the legal name is unknown and leave Item 53 blank.
54. Alternate name, e.g., AKA - individual or trade name, DBA - entity
Item 54 Alternate name: If the financial institution recorded in Item 53 has a separate doing
business as (DBA) name, enter that name here. If an individual recorded in Item 53 has a
separate also known as (AKA) name, enter that name here also. Do not include the acronyms
DBA or AKA with the alternate name.
* 55. TIN
a. (check if) unknown
Item 55 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the
financial institution or individual recorded in Item 53. See General Instruction 9 for information
on entering identifying numbers. Check box 55 “Unknown” if the TIN is unknown and leave
Item 55 blank.
56. TIN type (* if 55 is completed)
a. EIN
b. SSN-ITIN
c. Foreign
Item 56 TIN type: Select the option for the type of TIN entered in Item. If the TIN in Item 55 is
unknown and the Item 53 financial institution has a U.S. address, select TIN Type option “EIN”
if the financial institution is an entity and “SSN-ITIN” if the financial institution is an
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individual. If the financial institution has a foreign address and the TIN is unknown, select
“Foreign.”
* 57. Address
a. (check if) unknown
Items *57 - *61 Financial institution address items: Enter the financial institution's permanent
street address, city, two or three letter state/territory/province code (U.S./Canada/Mexico only),
ZIP Code or foreign postal code, and two letter country code. If an address item is unknown,
leave that item blank and check the item’s "Unknown" box. Leave Item 59 State blank if the state
is unknown or the country is not the U.S., Canada, or Mexico. See General Instruction 7 for
additional information on entering address data.
* 58. City
a. (check if) unknown
59. State
* 60. ZIP/Postal Code
a. (check if) unknown
* 61. Country
62. Internal control/file number
Item 62 Internal control/file number: Enter the internal control number or file number, if
applicable, assigned to the FinCEN SAR by the financial institution. This number should be
unique to the FinCEN SAR if possible, allowing interested parties such as law enforcement or
the financial institution to reference the FinCEN SAR without committing a potentially illegal
disclosure of FinCEN SAR data.
63. Loss to financial institution (if applicable)
Item 63 Loss to financial institution: If the financial institution has suffered a loss because of the
suspicious activity, record the amount of loss in Item 63. If some losses are known and other
losses unknown, enter the total of known losses as of the date of filing. If the FinCEN SAR is a
continuing FinCEN SAR because box 1c was checked, enter the loss amount for the current
FinCEN SAR in Item 63 and record in Part V the total aggregated losses for all FinCEN SARs
filed on the suspicious activity. The amount entered in this field cannot be zero and cannot be
greater than the amount in Item 26 “Amount involved in this report.” See General Instruction
10 for information on entering amounts.
64. Branch’s role in transaction (if applicable)
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a. (check if) Selling location
b. (check if) Paying location
c. (check if) Both a & b

Item 64 Branch’s role:
Check the box “Selling location” if the branch sold the products or instruments recorded in
Items 39 or 40 to a customer. Check the box “Paying location” if a customer received payment
from the branch for the products or instruments recorded in Items 39 or 40. Check the box
“Both” if the Part III financial institution branch was both a paying and selling location for the
products or instruments recorded in Items 39 or 40. This item must be blank if no branch is
involved in the suspicious activity. If multiple branches are involved in the suspicious activity,
a separate Item 64 must be prepared for each branch.
* 65. Address of branch or office where activity occurred
a. If no branch activity involved, check this box.
Items *65 and 67-70 Branch address items: See the instructions for Items *57 - *61 and General
Instruction 7 for information on entering address data. If a branch address item is unknown,
leave that item blank. Item 70 “Country” cannot be blank if any other branch address
information is recorded. If no branch was involved in the suspicious activity, check box 65a and
leave the branch address items blank. If multiple branches are involved in the suspicious
activity, complete a set of branch address items for each branch.
66. RSSD number (of the Branch)
Item 66 RSSD number: Enter the RSSD (Research Statistics Supervision Discount) number of
the branch, if known. If multiple branches are involved in the suspicious activity, complete Item
66 for each branch for which the RSSD number is known.
67. City
68. State
69. ZIP/Postal Code
70. Country (* if 65a is NOT selected) (2 letter code – list provided)

------------------------------- Part IV Filing Institution Contact Information -----------------------------

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Part IV records information about the lead financial institution, holding company, agency, or
other entity that is filing the FinCEN SAR. There must be only one Part IV record in a FinCEN
SAR. Do not include information about joint filers in a Part IV record. Joint filer information
must be reported in a Part III record. Financial institution as used in Part IV includes
individuals acting as sole proprietorship financial institutions using their personal Social
Security Number (SSN) or Individual Taxpayer Identification Number (ITIN).
* 78. Primary Federal Regulator (instructions specify banking agencies, SEC, CFTC, IRS)
a. Commodities Futures Trading Commission (CFTC)
b. Federal Reserve Board (FRB)
c. Federal Deposit Insurance Corporation (FDIC)
d. Internal Revenue Service (IRS)
e. National Credit Union Administration (NCUA)
f. Office of the Comptroller of the Currency (OCC)
g. Securities and Exchange Commission (SEC)
h. Federal Housing Finance Agency (FHFA)
z. Not Applicable.
Item *78 Primary federal regulator: Select the appropriate option from the drop-down list to
identify the Primary Federal Regulator or BSA Examiner of the filing institution. If more than
one regulator option could apply, select the regulator that has primary responsibility for
enforcing compliance with the BSA. If Item 82 option “Casino/Card Club,” “Insurance
Company,” or “MSB” is selected, the Item 78 entry must be “Internal Revenue Service (IRS).” If
the financial institution filing the FinCEN SAR is subject to U.S. law and none of the other codes
apply, the entry must be “Internal Revenue Service (IRS).” If the FinCEN SAR is being filed by a
government agency or if the financial institution filing the FinCEN SAR is not subject to U.S.
law, the entry must be "Not Applicable.”
* 79. Filer name (Holding company, lead financial institution, or agency, if applicable).
Item *79 Filer name: Enter the legal name of the filing institution as recorded on articles of
incorporation or other documents establishing the institution. Enter the full name of the filer if
the filer is an individual, such as a sole proprietorship, acting as a financial institution. If an
individual’s name is recorded, enter the name in (first name) (middle name) (last name) or
equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc.
* 80. TIN
Item *80 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the
financial institution or individual recorded in Item 79. See General Instruction 9 for information
on entering identifying numbers.
* 81. TIN type
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a. EIN
b. SSN/ITIN
c. Foreign
Item *81 - TIN type: Record the type of TIN entered in Item 81 by selecting the appropriate
option.
*82. Type of financial institution (check only one)
a. Casino/Card club
b. Depository institution
c. Insurance company
d. MSB
e. Securities/Futures
f. Loan or Finance Company
g. Housing GSE
z. Other (specify type of institution in space provided)
Item *82 - Type of financial institution: Select the appropriate type of financial institution that
best describes the filing institution recorded in Item 79. If none of those options apply, select
“Other” and enter a brief description in the associated text field. If necessary, include a moredetailed description in Part V.
NOTE: If the financial institution is a non-bank residential mortgage lender or originator, select
“Other” and enter “NON-BANK RESIDENTIAL MORTGAGE” in the associated text field. If
the financial institution is a dealer in precious metals, stones, or jewels, select option “Other”
and enter “DEALER IN PRECIOUS METALS STONES JEWELS” in the associated text field.
83. Type of Securities and Futures institution or individual filing this report—check box(es) for
functions that apply to this report
a. Clearing broker - securities
b. CPO/CTA
c. Futures Commission Merchant
d. Holding company
e. Introducing broker - commodities
f. Introducing broker - securities
g. Investment Adviser
h. Investment company
i. Retail foreign exchange dealer
j. SRO Futures
k. SRO Securities
l. Subsidiary of financial/bank holding company
z. Other (specify type of institution or individual in space provided)

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Item 83 - Securities and futures type: If option 82e “Securities/Futures” was selected, check all
boxes that apply to indicate the type of securities and futures institution that is filing the
FinCEN SAR. If none of options 83a through 83l apply, check box 83z "Other" and record a brief
description of the type in the associated text field. If necessary, include a more-detailed
description in Part V.
84. Filing institution identification number (Check one box to indicate type)
a. (check if) Central Registration Depository (CRD) number
b. (check if) Investment Adviser Registration Depository (IARD) number
c. (check if) National Futures Association (NFA) number
d. (check if) Research Statistics Supervision Discount (RSSD) number
e. (check if) Securities and Exchange Commission (SEC) number
f. (check if) National Association of Insurance Commissioners (NAIC Code)
g. (check if) Mortgage (NMLS ID)
h. Identification number
Item 84 - Filing institution identification number: See instructions for Item 51.
* 85. Address
Items 85-89 - Address: See instructions for Items 57 through 61.
* 86. City
87. State
* 88. ZIP/Postal Code
* 89. Country
90. Alternate name, e.g., AKA - individual or trade name, DBA – entity
Item 90 - Alternate name: See the instructions for Item 54.
91. Internal control/file number
Item 91 - Internal control/file number: See instructions for Item 62.
92. LE contact agency
Item 92 - LE contact agency: Enter the name of the law enforcement agency, if any, which has
been informed of the suspicious activity.

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NOTE: If more than one LE agency has been contacted about the suspicious activity, record the
information on one agency in Items 92-95 and the information on additional agencies in Part V.
93. LE contact name
Item 93 - LE contact name: Enter the name of the person contacted at the law enforcement
agency.
94. LE contact phone number
a. Extension (if any)
Item 94 - LE contact phone number: Enter the law enforcement contact telephone number. See
General Instruction 8 for information on entering telephone numbers.
Item 94a - Extension: Enter the extension, if any, of the law enforcement contact telephone
number.
95. LE contact date
Item 95 – LE contact date: Enter the most-recent date the law enforcement agency was
contacted about the suspicious activity. If the agency was contacted on multiple dates, record
the earlier contact dates in Part V.
* 96. Filing institution contact office
Item 96 - Filing institution contact office: Enter the name of the filing institution contact office
where additional information about the FinCEN SAR or supporting documentation can be
requested. If the FinCEN SAR is jointly filed, enter in Part V the contact office and telephone
number information for all Part III joint filers.
* 97. Filing institution contact office phone number including area code
a. Extension, if any
Item 97 - Filing institution contact office phone number: Enter the contact office telephone
number. See General Instruction 8 for additional instructions on entering telephone numbers.
Item 97a - Extension: Enter the extension, if any, of the contact office telephone number.
* 98. Date filed
Item 98 - Date filed: Enter the date the FinCEN SAR is filed. This date will be entered
automatically when a discrete FinCEN SAR is electronically filed.

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---------------------------- * Part V Suspicious Activity Information – Narrative ----------------------The narrative section of the report is critical to understanding the nature and circumstances of
the suspicious activity. The care with which the narrative is completed may determine whether
the described activity and its possible criminal nature are clearly understood by investigators.
Filers must provide a clear, complete, and concise description of the activity, including what
was unusual or irregular that caused suspicion. This description should encompass the data
provided in Parts I through III, but should include any other information necessary to explain
the nature and circumstances of the suspicious activity. Filers should provide any information
the filers believe necessary to better enable investigators to understand the reported suspicious
activity. Narratives must be completed in English. Filers should use the following checklist as a
guide for preparing the narrative:











If filers have additional information pertaining to items in Parts I through IV this
information should be recorded in the narrative and referenced to the item number.
If this report is a corrected or amended report, complete the report in its entirety with
whatever corrections or amendments were required. Describe the corrections or
amendments at the beginning of the narrative.
If this report is a continuing report, describe the circumstances surrounding the
suspicious activity for the 90-day period encompassing the report. Include information
from prior FinCEN SAR narratives only when it is necessary for an understanding of the
nature and circumstances of the suspicious activity. Never include the entire narratives
of the prior FinCEN SARs.
If any item in the report was insufficient for recording all item data held by the filer, or if
an item’s instructions require entry of additional data or explanation in the narrative,
record the additional data referenced by item number in the narrative.
Information provided in other sections of the FinCEN SAR need not be repeated in the
narrative unless necessary to provide a clear and complete description of the suspicious
activity.
Describe the conduct or transaction(s) that caused suspicion. If appropriate, this
description should be chronological when the activity involves multiple instances or
encompasses more than one day.
Explain whether any transaction(s) involved were completed or only attempted.
Explain who benefited and how they benefited, financially or otherwise, from the
activity.
Describe all supporting documentation and retain the documentation for five years. DO
NOT include supporting documentation with the FinCEN SAR. (See General Instruction
6.)
If the FinCEN SAR is jointly-filed, name all joint filers and describe the nature of
supporting document held by the joint filers. Provide the contact office name and
telephone number for each joint filer.
Describe and retain any evidence of cover-up or evidence of an attempt to deceive
federal or state examiners or others.

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

















Describe and retain any admission or explanation of the activity or transaction(s)
provided by the subject(s), witness(s), or other person(s), including to whom and when
it was given.
Indicate where the suspicious activity took place, e.g. branch, cage, gaming pit, agent
location, etc.
Indicate whether the suspicious activity is an isolated incident or related to other
activity.
Indicate whether any U.S. or foreign currency or other negotiable instruments were
involved. If foreign currency or other foreign instruments, provide the foreign amount,
currency name, and country of origin.
Indicate if there is any litigation related to the activity by specifying the name of the
litigation and court where the action is pending.
Describe the nature of losses and recoveries related to the suspicious activity, including
aggregated losses and recoveries in continuing activity.
Identify the names of financial institutions associated with account numbers when the
financial institution TINs were unknown.
If the subject is a foreign national provide all available information on the subject’s
passport(s), visa(s), and other identification. Include identifying data such as issuing
date, country, document numbers, issuing authority, and nationality.
If the suspicious activity involves transfers of funds to or from a foreign country or
currency exchanges involving foreign currencies, identify the foreign currency, country
of issue, and the source or destination of the funds.
If a subject involved in the suspicious activity has an insider relationship with a financial
institution, describe the subject’s position with the financial institution and how that
position related to the suspicious activity.
Indicate if any information was excluded from this report and explain the nature of the
excluded information and the reason(s) for exclusion.
Provide information on the victims of the suspicious activity only when it is necessary
for a complete understanding of the activity. DO NOT record victim information in a
Part I Subject Information record.
Provide information about the financial institution’s business policies and practices only
if it is necessary for a complete understanding of the suspicious activity. DO NOT
include legal disclaimers in the narrative.

Add Attachment:
Filers can include with a FinCEN SAR an attachment containing tabular data (such as
transaction data) that provides additional suspicious activity information not suitable for
inclusion in the narrative. This file must be an MS Excel-compatible comma separated value
(CSV) file with a maximum size of 1 megabyte. Discrete FinCEN SAR filers can attach this file
by clicking the “Add Attachment” button on the discrete FinCEN SAR header page and
following the instructions provided. Batch filers must follow the instructions in Attachment D –
Batch Attachments to add CSV files to a batch file.
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Attachment D – Batch Attachments
Institutions filing electronic FinCEN Suspicious Activity Reports (FinCEN SAR) may, but are
not required to, attach a Microsoft Excel-compatible comma separated values (CSV) file (no
larger than 1 MB) providing details in tabular form of transactions subject to the suspicious
activity discussed in Part V “Narrative Description” of the FinCEN SAR.
NOTE: Please be advised that when entering data into an Excel spreadsheet prior to saving it as
a comma separated (.CSV) file, the default behavior for numeric data entered into cells is to
convert numeric values over 11 characters into scientific notation. For example, the value of
123456789123 is converted to 1.23457E+11 after entry. When the Excel spreadsheet is saved to a
comma separated (.CSV) fill, this visible format is retained and when opened the entire original
number is not displayed, 123456789123, but rather 1.23457E+11.To avoid this behavior, please
ensure that your workbook cells are formatted as text prior to entering data in the cell. This can
be accomplished by selecting the column, right clicking the mouse and selecting Format Cells,
and then selecting Text under Category, and then OK. This must be done before entering the
data, not after.
While the BSA E-Filing System limits the number of attachments for a single FinCEN SAR to
one (1) CSV file, batch filers must abide by the following instructions in order to submit
attachments for one or more FinCEN SAR within their batch file:
1. Identify which FinCEN SARs in the batch are associated with attachments
Ensure attachment indicator—located in field position 8 of the Suspicious Activity
Information (3A) Record of the FinCEN SAR batch file—contains an “X,” which indicates
that the corresponding FinCEN SAR contains an attachment. The count (i.e. sum) of all
FinCEN SARs within the batch file that are associated with an attachment should appear
in the File Summary (9Z) Record (field position 45-51).
2. Reference the FinCEN SAR Transaction Sequence Number in your attachment file
name
When naming your attachment file for a particular FinCEN SAR, you must first locate the
unique transaction sequence number that has been assigned to the corresponding FinCEN
SAR within the batch file (see field position 3-7 of the Suspicious Activity Information (3A)
Record); you must reference the transaction sequence number at the beginning of your
attachment file name, followed by an underscore (i.e. “_”) and a descriptive name to help
identify the associated FinCEN SAR.

Attachment File Name Example

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3. Include all attachments (associated with the FinCEN SAR batch file) in a single zip file
Subsequent to the file renaming for all attachments associated with your batch file, you
must create a zip file composed of all attachments. When naming the zip file, be sure to
use a descriptive file name to help you identify which FinCEN SAR batch your attachment
zip file is associated with.

ZIP File Name Example

ZIP File Layout Example

4. Add the attachment zip file to the FinCEN SAR Batch Form prior to submission
Once all required fields are complete and your FinCEN SAR batch has been attached to
the FinCEN SAR Batch Form, locate the Add File button for attachments in order to add
your attachment zip file to the FinCEN SAR Batch Form. Once the attachment file is
attached, you may sign the FinCEN SAR Batch Form with your PIN, save, and submit.
Secure Data Transfer Mode Users
For filers using this option for filing, SDTM users can submit a single ZIP file containing the
FinCEN SAR batch data and the corresponding attachment data. The ZIP file is composed of
one FinCEN SAR batch data file and one attachment ZIP file. The attachment Zip file should
follow the BSAR attachment specification described above. The ZIP file name must start with
“BSARST.” and end with “.ZIP”. An example will be: BSARST.BSAR_batch.ZIP. FinCEN SAR
SDTM batch files without any attachment can follow the existing naming convention: BSARST.
. Only ZIP compressed files are supported for the
attachment file.
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Attachment E- Batch File Sample
Layouts
Submitting batch files in the correct format is vitally important because improperly formatted
files may be rejected and can result in data entering FinCEN’s System of Record database
incorrectly. Batch filers will use the Financial Institution Where Activity Occurred (2B) Record
and the Branch or Office Institution Where Activity Occurred (2C) Record for reporting
information about the location(s) of suspicious activity(s). The 2B record identifies information
regarding the financial institution where activity(s) occurred (required), whereas the 2C record
identifies the financial institution’s branch or office location where activity occurred (if
applicable). Filers are permitted to associate up to 99 2B records, as well as 99 2C records for
each 2B record, for a single suspicious activity report. However, filers are NOT permitted to
associate multiple Suspicious Activity Information (3A) Records under one or more shared
2B/2C records.
General Rules:

Following are general rules for creating batch files with the required record layout.
1. Records must be in alphanumeric order for each SAR in the batch and grouped
together according to their transaction sequence number. For example, a primary
Subject (4A) Record cannot precede a primary Suspicious Activity Information
(3A) Record if they both coincide with the same SAR in the batch. A subordinate
Subject Identification (4C) Record cannot precede a subordinate Subject Address
(4B) if they both coincide with the same primary Subject (4A) Record. The
transaction sequence number associated with the first SAR in the batch will be
“00001” and all subsequent records up to the Narrative (5A) Record associated
with the first SAR will share the same transaction sequence number.
2. Subordinate records must follow the specific primary record they are associated
with. A 4B record must follow the 4A record of the subject that has that address. A
Branch or Office Institution Where Activity Occurred (2C) Record must follow the
Financial Institution Where Activity Occurred (2B) Record of the financial
institution that owns that branch. Do not, for example, place all 4B records
following the last of multiple 4A records or all 2C records following the last of
multiple 2B records unless they are only associated with the last of multiple
records.
3. Individual subordinate records cannot be associated with multiple primary
records. If two primary 4A record subjects have the same address, each 4A record
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4.
5.
6.
7.

must be followed by a separate subordinate 4B record containing that address. A
4B record following a second 4A record is not associated with the first 4A record.
A 4B record following the first of two 4A records is not associated with the second
4A record.
There can be up to 99 of each of the subordinate 3B through 3F records associated
with each primary 3A record in a batch file.
There can be up to 99 of each of the subordinate 4B through 4I records associated
with each primary 4A record in a batch file.
There can be up to 20 Narrative Description (5A) Records associated with each
SAR in a batch file.
Do not include blank subordinate records in a SAR. If a subject does not have an
alternate name, there will be no Subject Alternative Name (4D) Record following
that subject’s 4A record in the SAR.
Do not include duplicate records in a SAR. A duplicate record occurs when one
record is directly followed by a second record of the same record type that contains
exactly the same data as the prior record.

Sample Layout:

Table 1 contains an example valid batch file record layout where multiple financial
institutions, branch/office locations, multiple subjects, and subsidiary records are included
designed to show the required positions and inclusion or exclusion of batch file records in
varying circumstances.

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Table 1 - Batch File Sample Layout

This batch file was transmitted by the 1A record transmitter for 2A record Filing Institutions A and B. Three SARs are filed under
the 2A record for Filing Institution A and one SAR is filed under the 2A record for Filing Institution B.

SAR1, Financial Institution A-1 and Branch A-1.1: A single subject is involved with suspicious activity at a single financial
institution and one branch location. This example contains all subsidiary 3B-3F and 4B-4I records to show their placement.

SAR2, Financial Institution A-1and Branch A-1.1: A single subject is involved with suspicious activity at a single financial
institution and one branch location. This example has a 3B commodity type record and a 3C product/instrument description type
record subordinate to the 3A record. The 4A record only has single 4B address, 4C identification, and 4H relationship records
followed by two 4I account records for two account numbers. This SAR has multiple 5A narrative sections.
SAR3, Financial Institution A-1and Branches A-1.1 and A-1.2, Financial Institution A-2 and Branch A-2.1: two subjects involved in
suspicious activity at two different financial institution, one with two branches and one with one branch. There are no subsidiary
records following the 3A record. Subject 1’s 4A record has single 4B address and 4C identification records and two 4H
relationship records, one for each 2B financial institution. Subject 2 has only one of various subsidiary records including one 4H
relationship record because Subject 2 has a relationship with only one of the institutions.

SAR4, Financial Institution B-1 with no branch activity and Financial Institution B-2 with Branches B-2.1 and B-2.2: A single subject
is involved in suspicious activity at two institutions, one with two branch locations. All information about the subject and the
subject’s possible relationship to the financial institutions is unknown.

Subordinate records have been indented for clarity.

Batch Layout
1A (Transmitter)
2A (Filing Institution A)
2B (Financial Institution A-1) (note: SAR1 begins)
2C (Branch A-1.1)
3A (Suspicious Activity Information)
3B (Commodity Type)
3C (Product/Instrument Description)
3D (Market)
3E (IP Address)
3F (CUSIP)
4A (Subject 1)
4B (S-1 Address)
4C (S-1 Identification)
4D (S-1 Alternate name)
4E (S-1 Telephone)

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4F (S-1 E-mail)
4G (S-1 Website URL)
4H (S-1 Relationship)
4I (S-1 Account)
5A (Narrative) (note: can have multiples)
9A (Summary of SAR1)
2B (FI A-1) (note: SAR2 begins)
2C (Branch A-1.1)
3A (Suspicious Activity Information)
3B (Commodity Type)
3C (Product/Instrument Description)
4A (Subject 1)
4B (S-1 Address)
4C (S-1 Identification)
4H (S-1 Relationship)
4I (S-1.1 Account)
4I (S-1.2 Account)
5A (Narrative)
5A (Narrative)
5A (Narrative)
9A (Summary of SAR2)
2B (FI A-1) (note: SAR3 begins)
2C (Branch A-1.1)
2C (Branch A-1.2)
2B (FI A-2)
2C (Branch A-2.1)
3A (Suspicious Activity Information)
4A (Subject 1)
4B (S-1 Address)
4C (S-1 Identification)
4H (S-1 Relationship)
4H (S-1 Relationship)
4A (Subject 2)
4B (S-1 Address)
4C (S-1 Identification)
4D (S-1 Alternate name)
4E (S-1 Telephone)
4F (S-1 E-mail)
4H (S-1 Relationship)

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4I (S-1 Account)
5A (Narrative)
9A (Summary of SAR3)
9B (Summary of Filer A)
2A (Filer B)
2B (FI B-1) (note: SAR4 begins)
2B (FI B-2)
2C (Branch B-2.1)
2C (Branch B-2.2)
3A (Suspicious Activity Information)
4A (Subject 1)
5A (Narrative)
9A (Summary of SAR4)
9B (Summary of Filer B)
9Z (Summary of Batch File)

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File Type	application/pdf
File Modified	2016-02-26
File Created	2015-03-12