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pdfFinancial Crimes Enforcement Network
Financial Crimes Enforcement Network (FinCEN)
FinCEN Suspicious Activity Report (FinCEN
SAR) Electronic Filing Requirements
XML Schema 2.0
User Guide
FinCEN SAR XML Schema User Guide (version 1.3 | January 2020)
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Financial Crimes Enforcement Network
DEPARTMENT OF THE TREASURY
FINANCIAL CRIMES ENFORCEMENT NETWORK (FINCEN)
FinCEN SAR XML Schema User Guide (version 1.5 | July 2020)
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Financial Crimes Enforcement Network
0. Revision History
Version
Number
Date
Change Description
1.0
01/26/2018
Initial version
1.1
06/15/2018
3.2 Batch Validation (Form & Fit) Overview
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Added the following bullet to the list of general schema requirements that all
XML batch files must adhere to:
o Element values must not include leading and/or trailing spaces.
o Element values must not include non-printable characters, such as
carriage returns, line feeds, and tabs.
o Element values must not contain duplicate entries within a single
activity unless expressly permitted (for example, a Subject party type
may contain one legal name and up to 99 alternate names; therefore,
if more than one legal name is recorded for the Subject, the batch file
will fail validation and will not be accepted).
4. FinCEN SAR XML Element Requirements
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AssetSubtypeID
o Added the following rejection criteria to the Remarks: “The element
contains a value that has already been recorded for the Activity.”
ActivityNarrativeSequenceNumber
o Added the following rejection criteria to the Remarks: “The element
contains a value that has already been recorded for the Activity.”
OrganizationSubtypeID
o Added the following rejection criteria to the Remarks: “The element
contains a value that has already been recorded for the Activity.”
SuspiciousActivitySubtypeID
o Added the following rejection criteria to the Remarks: “The element
contains a value that has already been recorded for the Activity.”
PartyName
o Added the following rejection criteria to the Remarks: “More than
one legal name is recorded for a party within a single FinCEN SAR
Activity.”
PartyIdentification
o Added the following rejection criteria to the Remarks: “More than
one identification (other than the Form of ID for the Subject) of the
same type is recorded for a party within a single FinCEN SAR
Activity.”
FormTypeCode
o Modified Value Restrictions and Example to correctly display the
expected value of “SARX” rather than “FinCEN SARX”.
CyberEventIndicatorsTypeCode
o Modified the Value Restrictions by changing the "Other" cyber event
indicator type code from "11" to "999". NOTE: This change has also
been applied to the EFL_SARXBatchSchema.xsd schema.
ElectronicAddressText
o Modified the Value Restrictions to specify that E-mail addresses
should be 50 characters or less while Website (URL) addresses can
be up to 517 characters and must contain at least one period.
OrganizationTypeID
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Modified the Value Restrictions by changing the "Other"
organization type code from "99" to "999". This is consistent with
the current XML schema.
OtherIssuerStateText
o Modified the Element Restrictions to include a third bullet that
instructs the filer to record the element when "The identification
type is Other and the identification was not issues by a national
government." In the event that the "Other" identification recorded is
a type of national government ID, such as a military ID, then the
OtherIssuerStateText should not be recorded; instead, the
OtherIssuerCountryText should be recorded identifying the Country
where the ID was issued by (or in) associated with the subject.
PartyIdentificationNumberText
o Modified the Value Restrictions to include a statement that
"asterisks within the identification number are accepted for the
subject's form of identification." This was added to accept
Washington State Driver's License numbers containing asterisks.
o Modified the Description of the Financial Institution Where Activity
Occurred for bullet "55. Filing institution identification" to "55.
Financial institution identification".
o Modified the Value Restrictions to include the following for the
Transmitter (35) TCC: TCC = 8 characters "equal to “TBSATEST”
(when submitting in the BSA E-Filing User Test System) or
“PBSA8180” (when submitting in the BSA E-Filing Production
System)".
PartyIdentificationTypeCode
o Modified the Description of the Financial Institution Where Activity
Occurred (bullet "55. Filing institution identification" to "55. Financial
institution identification".
PhoneNumberText
o Modified the Value Restrictions to include the following NOTE for
the Transmitter (35): "NOTE: This number must be the same for all
FinCEN SARs in the batch file."
RawPartyFullName
o Modified the Element Restrictions to include the following NOTE for
the Transmitter Contact (37): "(NOTE: The value recorded must be
the name of the individual to be contacted on issues involving the
batch file. This entry must be the same for all FinCEN SARs in the
batch file.)"
o Modified the Value Restrictions to include the following note for the
Contact Office (8): "(NOTE: This value recorded must be the title of
the administrative office (such as Compliance Office) that should be
contacted for additional information about the FinCEN SAR.)"
SuspiciousActivity
o Modified the Description by changing the maxOccurs associated
with the SuspiciousActivityClassification sub-element from “1” to
“99”.
Branch Address Elements:
o Party
Modified the Element Description by changing the Address
minOccurs from “0” to “1”.
o Address
o
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Modified the Element Description by changing the
minOccurs from “1” to “0” for the following: RawCityText,
RawStreetAddress1Text, and RawZIPCode.
RawCityText
Modified the Element Restrictions from “Required. This
element must be recorded if the parent element is
recorded” to “Record this element for the Branch (46)
where activity occurred party type when the city associated
with the branch address is known; otherwise, do not record
this element.”
Removed the following from the Remarks: “The batch
submission will be accepted with warnings if any of the
following conditions are true: The element is not recorded
or does not contain a value.
RawStreetAddress1Text
Modified the Element Restrictions from “Required. This
element must be recorded if the parent element is
recorded” to “Record this element for the Branch (46)
where activity occurred party type when the street address
associated with the branch address is known; otherwise, do
not record this element.”
Removed the following from the Remarks: “The batch
submission will be accepted with warnings if any of the
following conditions are true: The element is not recorded
or does not contain a value.
RawZIPCode
Modified the Element Restrictions from “Required. This
element must be recorded if the parent element is
recorded” to “Record this element for the Branch (46)
where activity occurred party type when the ZIP/Postal
Code associated with the branch address is known;
otherwise, do not record this element.”
Removed the following from the Remarks: “The batch
submission will be accepted with warnings if any of the
following conditions are true: The element is not recorded
or does not contain a value.
o
o
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6. FinCEN SAR XML Acknowledgement Format
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Added the following schema reference to the introductory paragraph: “Please
visit
https://www.fincen.gov/sites/default/files/schema/base/EFL_BatchAcknowled
gementSchema.xsd to access the FinCEN XML 2.0 batch acknowledgement
schema file.”
Added a more detailed diagram to section 6.1 XML File Structure.
Updated the Acknowledgement file examples.
Attachment A – Error Descriptions
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Updated Fatal error code A19 description from "Unknown file error. Please
contact the BSA E-Filing Help Desk for assistance" to "Schema validation
failure. The XML file does not conform to the defined schema located at
https://www.fincen.gov/base/EFL_SARXBatchSchema.xsd."
Removed Warning error code B8 "The element contains a value that is not
valid for the associated party type" (misc.) because it is not associated with
any particular field on the FinCEN SAR.
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Updated Fatal error code B9 as follows: "The element is not recorded or does
not contain a value." This is due to the fact that error code B7 is triggered if
the element is recorded but with no value (i.e. the value is null).
Modified Warning error code C25 to include the following: …and the county
code is US, CA, MX, "or a U.S. Territory."
Removed Warning error code D42 "The element is not recorded or does not
contain a value" for Item 70. Branch ID Number.
Removed Fatal error codes G17 "The element is recorded but without a value
(i.e. the value is null)" and G18 "The element contains a valid that is not a
valid code" because they are duplicates of G14 and G15, which have been
updated to be associated with both Transmitter TIN Type and Transmitter
Control Code (TCC) Type.
Removed the following Warning error codes associated with the Branch
Address sub-elements:
o D40 – The element is not recorded or does not contain a value
(RawStreetAddress1Text/69. Street)
o D43 – The element is not recorded or does not contain a value
(RawCityText/71. City)
o D48 – The element is not recorded or does not contain a value
(RawZIPCode/73. ZIP/Postal Code)
Modified Warning error code D46 as follows: “The element is not recorded or
does not contain a value when the country is US, CA, MX, or a U.S. Territory.
Attachment C – Electronic Filing Institutions
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1.2
10/1/2019
Modified the descriptions associated with 4. Continuing Reports as follows:
o Change "Continuing reports should be filed at least every 90-days..."
to "Continuing reports should be filed on successive 90-day review
periods..."
o Added the following directly after the above: until the suspicious
activity ceases, "but may be filed more frequently if circumstances
warrant that. Filers have up to 30 days following the end of a review
period to file the continuing report for a total of 120 days of review
and filing deadline."
Modified the description associated with 7. Addresses as follows:
o Removed the following reference: "U.S. State and Territory codes
must conform to the codes used by the United States Postal Service
as documented in ISO 3166-2:US."
Replaced the following 9.6.2 Item Instructions associated with Item 29
(Amount involved in this report) with what is currently recorded: “Item *29
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 29a "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 29b “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 29. See General
Instruction 9 for information on entering amounts.”
FinCEN SAR XML Element Requirements
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PartyAssociation
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o
o
o
Modified the element definition (additions underlined for emphasis):
“This is the container for information about the subject's
relationship to the institution recorded in the FinCEN SAR, as well as
information about the branch where activity occurred.”
Modified the element restrictions (additions underlined for
emphasis):
Record this element for the under the following circumstances;
otherwise do not record this element:
The party recorded is associated with the Subject (33) party
type in order to describe and the relationship of the
subject to the filing institution and/or the financial
institution(s) where activity occurred is being recorded;
otherwise, do not record this element. NOTE: If the subject
has no does not have a relationship with any of the above
recorded institutions in Part III or IV, record a single
element for the subject where the
element is
recorded with a "Y" value and the TIN of the filing
institution is recorded for the
element.
The element
should not be recorded for the subject if a relationship
exists with any institution recorded in Part III or IV, even
when there is no relationship with other institutions.
The party recorded is associated with the financial
institution where activity occurred (34) and activity
occurred at a branch location.
Modified the example to include an example of the Branch where
activity occurred.
FinCEN SAR Electronic Filing Instructions (Attachment C)
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General Instructions: 7. Address
o Added the following note to the end of the section text: “NOTE: The
ISO 3166-2 country list contains the code “UM” that stands for the
United State Minor Outlying Islands. Using “UM” in country fields is
prohibited. These islands are uninhabited. As such they have no
addresses.”
Part I Subject Information (introductory paragraph)
o Added Item 16 to the list of critical items that may be blank in the
event that Item 3b (all critical subject information is unavailable) is
indicated. Also corrected a typo that referenced Item 24 instead of
Item 27 as a critical item that is not included in the above rule.
Item 3 (check if…)
o Added Item 16 to the list of critical items that may be blank in the
event that Item 3b (all critical subject information is unavailable) is
indicated. Also corrected a typo that referenced Item 25 instead of
Item 27 as a critical item that is not included in the above rule.
Item 24 (Relationship of the subject to an institution…)
o Corrected a type referencing the Institution EIN as Item “23a”
instead of “24a”.
Item 31 (Cumulative amount…)
o Modified the title as follows: Cumulative amount (only applicable
when if box 1c (c ”Continuing activity report”) is checked in Item 1)
Item 27 (Financial Instituiotn TIN and account numbers)
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Modified 27a title from “account” to “accounts”.
Modified title of description parapgraph from “acct.” to “account”.
Added the following text to the item instructions (underlined for
emphasis): Check box 27a "No known acct. involved" if no account
related to the subject is involved in the suspicious activity. If box 27a
is checked, then all other options in Item 27 will be blank.
Part V Suspicious Activity Information – Narrative
o Added the following bullet to the narrative instructions: “If this SAR
contains information provided by another financial institution under
the 314(b) Voluntary Information Sharing Program, include in the
narrative the statement “This SAR contains 314(b) data.”
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1.3
01/08/2020
Secure Data Transfer Mode Filers
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1.4
02/10/2020
Remove C5 Error Code and Description
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1.5
07/07/2020
Includes reference to IBM Connect:Direct software replacement with IBM
Sterling File Gateway, as well as a more detailed breakdown of the required
batch file naming convention.
Updated to remove the error code C5 when a gender is not specified for the
individual subject.
Fixed the typo “acctount” to “account” on page 152.
Attachment C: General Instructions
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13. Reporting Cyber Events (Example 1). Updated the email address listed for
the Item 44f1 example to display the malicious email address
([email protected]) as opposed to the legitimate (victim) email address
([email protected]). In this example, the victim information should be
recorded in the narrative only.
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Contents
0.
Revision History..................................................................................................................................................................................................... iii
Contents ............................................................................................................................................................................................................................ ix
1.
Introduction ............................................................................................................................................................................................................. 1
2.
FinCEN SAR XML Schema Overview .............................................................................................................................................................. 1
2.1.
3.
4.
File Organization ...................................................................................................................................................................................... 1
2.1.1.
XML declaration (prolog) ................................................................................................................................................................ 1
2.1.2.
EFilingBatchXML ................................................................................................................................................................................. 1
2.1.3.
Activity .................................................................................................................................................................................................... 2
2.1.4.
Party ......................................................................................................................................................................................................... 3
2.1.5.
SuspiciousActivity............................................................................................................................................................................... 4
FinCEN SAR XML Batch Reporting Requirements ................................................................................................................................... 5
3.1.
Element Definition Overview............................................................................................................................................................... 5
3.2.
Batch Validation (Form & Fit) Overview ......................................................................................................................................... 6
FinCEN SAR XML Element Requirements .................................................................................................................................................... 6
4.1.
XML declaration/prolog ........................................................................................................................................................................ 6
4.2.
EFilingBatchXML Elements ................................................................................................................................................................... 6
4.3.
Activity Elements ...................................................................................................................................................................................... 8
4.4.
ActivityAssociation Elements ........................................................................................................................................................... 10
4.5.
ActivitySupportDocument Elements ............................................................................................................................................. 13
4.6.
Party Elements........................................................................................................................................................................................ 14
4.6.1.
PartyName Elements...................................................................................................................................................................... 27
4.6.2.
Address Elements ............................................................................................................................................................................ 35
4.6.3.
PhoneNumber Elements .............................................................................................................................................................. 42
4.6.4.
PartyIdentification Elements ....................................................................................................................................................... 45
4.6.5.
OrganizationClassificationTypeSubtype Elements ............................................................................................................ 52
4.6.6.
PartyOccupationBusiness Elements......................................................................................................................................... 57
4.6.7.
ElectronicAddress Elements ........................................................................................................................................................ 58
4.6.8.
PartyAssociation Elements .......................................................................................................................................................... 60
4.6.9.
PartyAccountAssociation Elements ......................................................................................................................................... 77
4.7.
4.7.1.
SuspiciousActivity Elements ............................................................................................................................................................. 84
SuspiciousActivityClassification Elements ............................................................................................................................. 88
4.8.
ActivityIPAddress Elements............................................................................................................................................................... 94
4.9.
CyberEventIndicators Elements....................................................................................................................................................... 95
4.10.
Assets Elements ..................................................................................................................................................................................... 99
4.11.
AssetsAttribute Elements ................................................................................................................................................................. 102
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4.12.
5.
6.
Party Elements by Party Type ...................................................................................................................................................................... 106
5.1.
Transmitter Party Record Example .............................................................................................................................................. 108
5.2.
Transmitter Contact Party Record Example ............................................................................................................................. 109
5.3.
Filing Institution Party Record Example..................................................................................................................................... 109
5.4.
Designated Contact Office Party Record Example................................................................................................................ 110
5.5.
Law Enforcement Agency Party Record Example .................................................................................................................. 110
5.6.
Law Enforcement Name Party Record Example ..................................................................................................................... 110
5.7.
Financial Institution Where Activity Occurred Party Record Example .......................................................................... 110
5.8.
Branch Where Activity Occurred Party Record Example .................................................................................................... 111
5.9.
Subject Party Record Example ....................................................................................................................................................... 112
5.10.
Financial Institution Where Account is Held Party Record Example ............................................................................. 113
FinCEN SAR XML Acknowledgement Format ....................................................................................................................................... 114
6.1.
XML File Structure .............................................................................................................................................................................. 114
6.1.1.
XML declaration/prolog ............................................................................................................................................................. 114
6.1.2.
EFilingBatchXML ............................................................................................................................................................................ 114
6.1.3.
EFilingSubmissionXML ................................................................................................................................................................ 115
6.1.4.
EFilingActivityXML......................................................................................................................................................................... 115
6.1.5.
EFilingActivityErrorXML............................................................................................................................................................... 116
6.2.
7.
ActivityNarrativeInformation Elements ...................................................................................................................................... 104
Acknowledgement XML Example ................................................................................................................................................ 118
Attachment A – Error Descriptions ........................................................................................................................................................... 119
7.1.
Miscellaneous Errors .......................................................................................................................................................................... 119
7.2.
Document Errors ................................................................................................................................................................................. 120
7.3.
Subject Information Errors .............................................................................................................................................................. 125
7.4.
Financial Institution & Branch Where Activity Occurred Errors....................................................................................... 128
7.5.
Filing Institution Errors ..................................................................................................................................................................... 131
7.6.
Attachment & Narrative Errors ..................................................................................................................................................... 133
7.7.
Transmitter Errors ............................................................................................................................................................................... 134
7.8.
Transmitter Contact Errors .............................................................................................................................................................. 135
8.
Attachment B – Error Correction Instructions ...................................................................................................................................... 136
9.
Attachment C – Electronic XML Filing Instructions ................................................................................................................................ 138
9.1.
Confidentiality of FinCEN SARs: .................................................................................................................................................... 138
9.2.
FinCEN SAR Sharing: .......................................................................................................................................................................... 138
9.3.
Prohibition on Disclosures by Financial Institutions: ........................................................................................................... 138
9.4.
Prohibition on Disclosures by Government Authorities: .................................................................................................... 139
9.5.
FinCEN SAR Filing Instructions: ..................................................................................................................................................... 139
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9.6.
FinCEN SAR Electronic Filing Instructions ................................................................................................................................. 141
9.6.1.
General Instructions: .................................................................................................................................................................... 141
9.6.2.
Item Instructions: ........................................................................................................................................................................... 146
10.
Attachment D – Secure Data Transfer Mode Filers .................................................................................................................... 169
11.
Attachment E – Supporting Documentation (Attachments) .................................................................................................. 170
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1. Introduction
The FinCEN Suspicious Activity Report (FinCEN SAR) XML Schema 2.0 User Guide outlines the business and validation
rules to support the electronic batch transmission of the FinCEN SAR. Electronic filing of this report will be through
the Bank Secrecy Act (BSA) E‐Filing System operated by the Financial Crimes Enforcement Network (FinCEN). BSA EFiling users who intend to file the FinCEN SAR batch XML should be familiar with FinCEN regulations, Extensible
Markup Language (XML) and the FinCEN XML schemas. For more information, please go to bsaefiling.fincen.treas.gov.
2. FinCEN SAR XML Schema Overview
Before you begin submitting your BSA data to FinCEN’s BSA E-Filing System (bsaefiling.fincen.treas.gov) via XML
batch, you must first review the required schemas to assist you with constructing and testing your XML batch file
before submitted to FinCEN for processing. These schemas define the requirements by which the FinCEN SAR XML
batch file must be constructed, such as which elements are required and which are optional, what are the appropriate
values you may enter for certain elements, and what sequence the elements should appear in when building the
batch. Please visit https://www.fincen.gov/sites/default/files/schema/base/EFL_FinCEN SARXBatchSchema.xsd to
access the FinCEN XML 2.0 batch schema file.
2.1. File Organization
This section describes the general formatting requirements for FinCEN SAR XML batch reporting. The diagrams that
follow provide a visual representation of the XML batch file layout from a high level perspective.
2.1.1. XML declaration (prolog)
The XML declaration specifies the XML version and character encoding used in the file. It must appear on the first line
of the file.
2.1.2. EFilingBatchXML
This is the root element and serves as the container for all FinCEN SAR documents recorded in the batch. It must be
the first element recorded in the file.
The EFilingBatchXML element is parent to the following complex element(s):
•
Activity. This element is the container for each FinCEN SAR document in the batch. All BSA data related to a
single FinCEN SAR document must be recorded within the element. The number of
elements will depend on the number of FinCEN SAR documents being reported in the batch.
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2.1.3. Activity
Each FinCEN SAR document in the batch must begin with the element. It identifies all information related
to a single FinCEN SAR, including (but not limited to) the transmitter, the reporting financial institution (i.e. filing
institution), the financial institution(s) where activity occurred, the subject(s), and suspicious activity details such as the
total amount involved, type(s) of suspicious activities, etc. There is no limit to the number of elements that
may be recorded in the batch; however, the total size of the batch file must not exceed 60MB.
The element is parent to the following complex element(s):
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ActivityAssociation. This element is the container for the type of filing (i.e. Initial report, Correct/amend
prior report, Continuing activity report, and/or Joint filing) for the FinCEN SAR.
ActivitySupportDocument. This element is the container for information about the supporting document
as an attachment to the FinCEN SAR being filed.
Party. This element is the container for any person (individual or entity) associated with the FinCEN SAR,
specifically, the transmitter [of the batch file], the transmitter contact, the filing institution and contact office,
the law enforcement contact agency and point of contact, the financial institution where activity occurred,
and the subject. NOTE: The financial institution where an account is held and the branch location where
activity occurred are not recorded at the activity level, but rather, within the corresponding party at the
activity level that the financial institution and/or branch are associated with.
SuspiciousActivity. This element is the container for information about the suspicious activity, such as the
total amount involved and the type of suspicious activity.
ActivityIPAddress. This element is the container for information about IP address involved in the suspicious
activity.
CyberEventIndicators. This element is the container for information about cyber event involved in the
suspicious activity.
Assets. This element is the container for information about asset involved in the suspicious activity,
specifically the product type, instrument type, and/or payment mechanism.
AssetsAttribute. This element is the container for information about the asset attribute involved in the
suspicious activity, whether it be a type of commodity, product/instrument, market where traded, and/or
CUSIP number.
ActivityNarrativeInformation. This element is the container for information about narrative description
associated with the FinCEN SAR.
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2.1.4. Party
Each FinCEN SAR activity in the batch must include a separate Party element identifying the following persons:
Transmitter, Transmitter Contact, Filing Institution, Designated Contact Office, Law Enforcement Agency (if any), Law
Enforcement Name (if any), Financial Institution(s) Where Activity Occurred, Branch(s) Where Activity Occurred (if any),
and Subject(s) (Note: If reporting account information related to a subject, the financial institution where the account
is held will be recorded as a separate Party element as well.). A maximum occurrence of 1203 total Party elements
may be recorded at the activity level for each FinCEN SAR activity in the batch. If one or more branches and/or
financial institutions where accounts are held are associated with a FinCEN SAR, a maximum of 99 branches and 99
financial institutions (where accounts are held) may be recorded for the FinCEN SAR in addition to the 1203 maximum
mentioned above.
Transmitter (Required)
This is the person (individual or entity) handling the data accumulation and formatting of the batch file. Each
FinCEN SAR Activity element in the batch must include a Party element that identifies the batch transmitter. The
batch transmitter should be identical for each FinCEN SAR. There must be only one occurrence of this party for
each FinCEN SAR Activity in the batch.
Transmitter Contact (Required)
This is the official contact for the transmitter. Each FinCEN SAR Activity element in the batch must include a Party
element that identifies the point of contact for the batch transmitter. The transmitter contact should be identical
for each FinCEN SAR. There must be only one occurrence of this party for each FinCEN SAR Activity in the batch.
Filing Institution (Required)
This is the entity responsible for filing the FinCEN SAR, such as a reporting financial institution or a holding or
other parent company filling for its subsidiaries. There must be only one occurrence of this party for each FinCEN
SAR Activity in the batch. This party corresponds with Part IV of the FinCEN SAR.
Designated Contact Office (Required)
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This is the administrative office that should be contacted to obtain additional information about the FinCEN SAR.
There must be only one occurrence of this party for each FinCEN SAR Activity in the batch. This party corresponds
with Part IV (Items 93-94) of the FinCEN SAR.
LE Contact Agency (if any)
This is the law enforcement agency (if any) that has been informed of the suspicious activity. There may only be
one occurrence of this party for each FinCEN SAR Activity in the batch. This party corresponds with Part IV (Item
89) of the FinCEN SAR.
LE Contact Name (if any)
This is the person at law enforcement agency (if any) contacted regarding the suspicious activity. There may only
be one occurrence of this party for each FinCEN SAR Activity in the batch. This party corresponds with Part IV
(Items 90-92) of the FinCEN SAR.
Financial Institution Where Activity Occurred (Required)
This is the financial institution where the suspicious activity occurred. There must be at least one occurrence (not
to exceed 99) of this party for each FinCEN SAR Activity in the batch. This party corresponds with Part III (Items
51-67, 69a). If a branch location associated with the financial institution where activity occurred is also involved,
information about the branch should be recorded in a separate party element under the parent element
(see PartyAssociation below).
Branch Where Activity Occurred (if any)
This is the branch location where activity occurred. 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. Generally, a branch
operates under the same TIN as the financial institution. No more than 99 branches may be recorded for each
FinCEN SAR in the batch. This party corresponds with Part III (Items 68-74) of the FinCEN SAR.
Subject (Required)
This is the subject involved in the suspicious activity. There must be at least one occurrence (not to exceed 999)
of this party for each FinCEN SAR Activity in the batch. This party corresponds with Part I (Items 3-28) of the
FinCEN SAR. Persons who are victims of the suspicious activity are not subjects and should not be recorded for
this party. Victim information, if necessary for a complete description of the suspicious activity, should be
recorded in the narrative. If the subject is or all subjects are unknown, record a single party for the subject with
“all critical subject information unavailable” indicated and record the nature of the unknown subject(s) in the
narrative. If the suspicious activity involves known and unknown subjects, record a separate party for each known
subject and record the nature of the unknown subject(s) in the narrative (when there are known subjects
involved, do not include a party element for unknown subjects.).
2.1.5. SuspiciousActivity
As the container for information about the details of the suspicious activity, this element identifies information such
as the total amount involved and the type of suspicious activity. This element must be recorded after the final Party
element is recorded for the FinCEN SAR. There must only be one occurrence of this element for each FinCEN SAR
Activity in the batch. This element corresponds with Part II (Items 29-31) of the FinCEN SAR.
Within this element is the sub-element , which must be recorded at least once per
FinCEN SAR (but no more than 99 total). This element is the container for information about the specific type(s) and
subtype(s) of suspicious activity, such as Structuring”Transaction(s) below CTR threshold”, Terrorist
financing”Known or suspended terrorist/terrorist group”, etc. This element corresponds with Part II (Items 32-42) of
the FinCEN SAR.
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3. FinCEN SAR XML Batch Reporting Requirements
This section describes in detail the reporting requirements for each element in the FinCEN SAR batch.
3.1. Element Definition Overview
Each element in this user guide is defined using the following terms:
Item
Element Name
minOccurs/maxOccurs
Description
This is the name that must be used when recording the element.
This defines the number of times the element can occur for the parent element.
•
•
Description
Attribute(s)
Parent Element
Element Restriction(s)
This is the summary description of the element. Also included in the description is
a list of sub-elements associated with the element (if applicable) as well as any
special requirements for when (and when not) to record the element.
This specifies the attribute(s) that are required to be recorded for the element.
Note: Various elements contain the SeqNum attribute used to identify the
associated element in the batch file. The value recorded for this attribute must be
numeric and unique.
This identifies the element’s container element. The element contains
sub elements and is considered a complex element.
This specifies the requirement level for the element; specifically, under what
conditions the element should be recorded:
•
•
Value Restriction(s)
Required. A value must be recorded for the element.
Conditionally Required. A value may or may not be recorded for the
element depending on whether or not certain conditions apply.
This specifies any additional information about the element to assist with
reporting; including:
•
•
Example
Required. The element must be recorded for the element.
Conditionally Required means that the element should only be recorded
when certain conditions apply.
NOTE: If neither of the above requirement levels are specified in this field,
then the element is not required. However, a field that is not required does
not mean that it is optional. All fields require an entry when the filer has the
relevant data.
This specifies any requirements and/or restrictions in terms of the value recorded
for the element.
•
•
Remarks
MinOccurs. The minimum number of times this element may be recorded
for the parent element (e.g. minOccurs=0 means this element is only required
under certain conditions while minOccurs=1 means at least one of the
element must be recorded for the parent element in the FinCEN SAR.)
MaxOccurs. The maximum number of times this element may be recorded
for the parent element (e.g. maxOccurs=999 means this element can occur
up to 999 times in the same FinCEN SAR.)
Reporting conditions that may result in a batch rejection.
Reporting conditions that may result in a batch accepted with warnings.
This provides one or more examples of how to record the element.
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3.2. Batch Validation (Form & Fit) Overview
IMPORTANT: FinCEN strongly encourages that filers first test their XML batch files for schema compliance using
the schemas available at www.fincen.gov/base. Your batch file should pass schema validation before you attempt
to submit to FinCEN; otherwise, it will be at risk of being rejected.
It is important to note that if the batch file does not adhere to the basic format described in this guide in accordance
with the FinCEN SAR XML batch schema, then the batch will fail validation and will not be accepted by FinCEN.
Here is a list of general schema requirements that your batch must adhere to in addition to the data requirements
described for each element throughout this guide. These schema requirements apply to all elements in the batch:
•
•
•
•
•
•
•
•
•
•
Element names must include the prefix “fc2” in both the opening tag and closing tag.
Element names must be spelled correctly and in the correct case. Do NOT included spaces at the beginning
or ending of the element names.
Elements must have a matching closing tag (which includes a self-closing tag in the event that no value is
recorded for the element).
Elements must be in the correct sequence.
Elements must be recorded when the minOccurs=1 (or greater than 1).
Elements must not be recorded more than the maxOccurs value for the associated element.
Element values must not exceed the maximum specified character limit.
Element values must not include leading and/or trailing spaces.
Element values must not include non-printable characters, such as carriage returns, line feeds, and tabs.
Element values must not contain duplicate entries within a single activity unless expressly permitted (for
example, a Subject party type may contain one legal name and up to 99 alternate names; therefore, if more
than one legal name is recorded for the Subject, the batch file will fail validation and will not be accepted).
4. FinCEN SAR XML Element Requirements
The following defines each element in the FinCEN SAR XML batch in the order in which they can be recorded.
4.1. XML declaration/prolog
Element Name:
?xml
Description:
XML declaration/prolog. This is the XML declaration which specifies the XML version and character
encoding used in the file. The XML declaration must appear on the first line of the file.
Attribute(s):
minOccurs:
1
Name
Description
version
The version number of the XML. The value recorded must be “1.0”
encoding
The character encoding, which must be UTF-8, used for the XML. The
value recorded must be “UTF-8”
n/a
Element Restriction(s):
This declaration must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Example:
1
The following data must be recorded for XML declaration/prolog:
Parent Element:
Remarks:
maxOccurs:
The batch submission will be rejected if any of the following conditions are true:
•
The XML declaration/prolog is not recorded with the required values (see Value Restriction(s)
above) or it is not recorded on the first line of the batch file.
4.2. EFilingBatchXML Elements
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Element Name:
EFilingBatchXML
minOccurs:
1
Description:
XML batch (header). This is the container for the contents of the batch file. This element is the root
element in the FinCEN SAR XML batch file and the container element for all suspicious activities
included in the batch. As the root element, it must be the first element recorded in the file, directly
following the XML declaration/prolog. The following sub-elements are associated with this element:
Name
Attribute(s)
maxOccurs:
minOccurs
maxOccurs
FormTypeCode
1
1
Activity
1
unbounded
1
Category
Simple
Complex
The following attributes must be recorded for this element:
Name
Description
ActivityCount
The count of all elements in the batch
TotalAmount
The sum of all element amounts
recorded in the batch
PartyCount
The count of all elements in the batch where the
is equal to “33” (Subject)
ActivityAttachmentCount
The count of all elements in the batch where the
element is recorded with a value
referencing the file name of the FinCEN SAR attachment
AttachmentCount
The count of all elements in the
batch that contain a value referencing the file name of the FinCEN
SAR attachment
xsi:schemaLocation
www.fincen.gov/base https://www.fincen.gov/base/EFL_FinCEN
SARXBatchSchema.xsd
xmlns:xsi
http://www.w3.org/2001/XMLSchema-instance
xmlns:fc2
www.fincen.gov/base
Parent Element:
n/a
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
One or more of the attributes are missing, incorrectly formatted, or contain an invalid value.
•
The reported attribute count does not match the actual count.
Example:
Element Name:
FormTypeCode
Description:
Form type (code). This element identifies the type of form being reported in the batch.
minOccurs:
Attribute(s)
n/a
Parent Element:
EFilingBatchXML
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must equal: SARX
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The value is null or not equal to FinCEN SARX.
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Element Name:
FormTypeCode
minOccurs:
Example:
SARX
Element Name:
Activity
1
maxOccurs:
1
maxOccurs:
unbounded
See Activity Elements for details.
4.3. Activity Elements
Element Name:
Activity
Description:
minOccurs:
Activity (header). This is the container for all information related to the FinCEN SAR. The first
element in the batch file must directly follow the element. The batch must contain at
least one occurrence of this element. There is no maximum occurrence value set for this element;
however, the total size of the batch file must not exceed 60MB. The following sub-elements are
associated with this element:
Name
Attribute(s)
1
minOccurs
maxOccurs
EFilingPriorDocumentNumber
0
1
Simple
FilingDateText
1
1
Simple
FilingInstitutionNotetoFinCEN
0
1
Simple
ActivityAssociation
1
1
Complex
ActivitySupportDocument
0
1
Complex
Party
6
1203
Complex
SuspiciousActivity
1
1
Complex
ActivityIPAddress
0
99
Complex
CyberEventIndicators
0
99
Complex
Assets
0
31
Complex
AssetsAttribute
0
396
Complex
ActivityNarrativeInformation
1
1
Complex
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
EFilingBatchXML
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
Category
31000000000001
20171101
Filing institution note to
FinCEN
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Element Name:
EFilingPriorDocumentNumber
Description:
Prior report BSA Identifier (number). This element identifies the BSA Identifier (BSA ID) of the
previously-filed FinCEN SAR when filing a correction/amendment and/or a continuing activity report.
This element corresponds with the following item(s):
•
1e. Prior report BSA Identification Number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Activity
Element Restriction(s):
Conditionally Required. Record this element when the FinCEN SAR being filed corrects/amends a prior
report and/or is a continuing activity report; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: 14-digit numeric BSA ID (if known); 14
consecutive zeros, i.e. “00000000000000” (if the BSA ID is unknown).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded but without a value (i.e. the value is null).
•
The value recorded does not equal 14 numeric characters.
•
The element is not recorded and one or both of the following elements contains a “Y” value:
o
o
•
The element is recorded (with a valid value) and none of the of the following elements
contains a “Y” value:
o
o
31000000000001
Element Name:
FilingDateText
Description:
Date filed (date). This element identifies the date in which the FinCEN SAR is being filed electronically
through FinCEN’s BSA E-Filing System. This element corresponds with the following item(s):
•
95. Date filed
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Activity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but without a value (i.e. the value is null).
•
The value recorded for the element is not a valid date in the format YYYYMMDD.
•
The value recorded for the element is a date greater than the current date or less than
January 1, 2000.
Remarks:
Example:
minOccurs:
1
maxOccurs:
1
20171101
Element Name:
FilingInstitutionNotetoFinCEN
Description:
Filing Institution Note to FinCEN (text). This element allows the filer to alert FinCEN that this FinCEN SAR
is being filed in response to a current specific geographic targeting order (GTO) or advisory or other
activity. This element corresponds with the following item(s):
•
2. Filing Institution Note to FinCEN
Please refer to Attachment C for additional information regarding the above item(s).
minOccurs:
Attribute(s)
n/a
Parent Element:
Activity
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1
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Element Name:
FilingInstitutionNotetoFinCEN
Element Restriction(s):
Record this element when the FinCEN SAR being filed is in response to a current specific geographic
targeting order (GTO) or advisory or other activity; otherwise, do not record this element.
Value Restriction(s):
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: 50 characters or less
Remarks:
n/a
Example:
Filing institution note to
FinCEN
Element Name:
ActivityAssociation
See ActivityAssociation Elements for details.
Element Name:
ActivitySupportDocument
See ActivitySupportDocument Elements for details.
Element Name:
Party
See Party Elements for details.
Element Name:
SuspiciousActivity
See SuspiciousActivity Elements for details.
Element Name:
ActivityIPAddress
See ActivityIPAddress Elements for details.
Element Name:
CyberEventIndicators
See CyberEventIndicators Elements for details.
Element Name:
Assets
See Assets Elements for details.
Element Name:
AssetsAttribute
See AssetsAttribute Elements for details.
Element Name:
ActivityNarrativeInformation
See ActivityNarrativeInformation Elements for details.
4.4. ActivityAssociation Elements
Element Name:
ActivityAssociation
minOccurs:
Description:
Type of filing (header). This element is the container for information about the type of filing associated
with the FinCEN SAR. The following sub-elements are associated with this element:
Name
1
maxOccurs:
1
minOccurs
maxOccurs
ContinuingActivityReportIndicator
0
1
Simple
InitialReportIndicator
0
1
Simple
CorrectsAmendsPriorReportIndicator
JointReportIndicator
*At least one of the above sub-elements must be recorded.
0
0
1
1
Category
Simple
Simple
This element corresponds with the following item(s):
•
1. Type of filing
o
1a. Initial report
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Element Name:
ActivityAssociation
minOccurs:
1
Attribute(s)
The following attributes must be recorded for this element:
maxOccurs:
o
1b. Correct/Amend prior report
o
1c. Continuing activity report
o
1d. Joint report
Please refer to Attachment C for additional information regarding the above item(s).
1
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
•
The element is recorded but none of the following sub-elements are recorded with a “Y”
value:
o
o
o
The batch submission will be accepted with warning if any of the following conditions are true:
•
The following sub-element combinations are recorded with a “Y” value:
o
AND ( AND/OR
)
Example:
Y
Y
Element Name:
ContinuingActivityReportIndicator
Description:
Continuing activity report (indicator). This element declares that the FinCEN SAR being filed continues
reporting on a previously-reported suspicious activity. This element corresponds with the following
item(s):
•
1c. Continuing activity report
Please refer to Attachment C for additional information regarding the above item(s).
minOccurs:
0
maxOccurs:
1
Attribute(s)
n/a
Parent Element:
ActivityAssociation
Element Restriction(s):
Conditionally Required. Record this element when the FinCEN SAR being filed continues reporting on a
previously-reported suspicious activity; otherwise, do not record this element.
If this element is recorded, the following elements must also be recorded:
•
•
Value Restriction(s):
The element may be recorded on its own or in conjunction with
one or both of the following "Type of filing" elements:
•
•
The value provided must adhere to the following requirements: "Y" (to indicate "Continuing activity
report")
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Element Name:
Remarks:
Example:
ContinuingActivityReportIndicator
minOccurs:
0
maxOccurs:
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
1
Y
Element Name:
CorrectsAmendsPriorReportIndicator
minOccurs:
0
maxOccurs:
1
Description:
Corrects/Amends prior report (indicator). This element declares that the FinCEN SAR being filed corrects
or amends a previously-filed FinCEN SAR. This element corresponds with the following item(s):
•
1b. Correct/Amend prior report
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityAssociation
Element Restriction(s):
Conditionally Required. Record this element when the FinCEN SAR being filed corrects or amends a
previously-filed FinCEN SAR; otherwise, do not record this element.
If this element is recorded, the following element must also be recorded:
•
Value Restriction(s):
Remarks:
Example:
The element may be recorded on its own or in conjunction with
one or both of the following "Type if filing" elements:
•
•
The value provided must adhere to the following requirements: "Y" (to indicate "Continuing activity
report")
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
InitialReportIndicator
minOccurs:
0
maxOccurs:
1
Description:
Initial report (indicator). This element declares that the FinCEN SAR being filed is the first report filed on
the suspicious activity. This element corresponds with the following item(s):
•
1a. Initial report
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityAssociation
Element Restriction(s):
Conditionally Required. Record this element when the FinCEN SAR being filed is the first report filed on
the suspicious activity; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The element may be recorded on its own or in conjunction with the following
"Type of filing" element:
•
The value provided must adhere to the following requirements: "Y" (to indicate "Initial report")
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
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Element Name:
JointReportIndicator
minOccurs:
0
maxOccurs:
1
Description:
Joint report (indicator). This element declares that the FinCEN SAR is being filed jointly by two or more
financial institutions. This element corresponds with the following item(s):
•
1d. Joint report
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityAssociation
Element Restriction(s):
Conditionally Required. Record this element when the FinCEN SAR is being filed jointly by two or more
financial institutions; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The element must be recorded in conjunction with at least one of the following
"Type of filing" element:
•
•
•
Furthermore, the element should not be recorded if one or more of the
following “subject relationship to institution” elements are indicated:
•
•
•
•
The value provided must adhere to the following requirements: "Y" (to indicate "Joint report")
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
4.5. ActivitySupportDocument Elements
Element Name:
ActivitySupportDocument
minOccurs:
Description:
Supporting Document (header). This element is the container for information about the supporting
document as an attachment to the FinCEN SAR being filed. The contents of the attachment file must be
described in the narrative. The attachment file would be most suitable for documenting transaction
records that are too numerous to record in the narrative. Do not include any other supporting
documentation with the FinCEN SAR. Instead, describe in narrative other supporting documentation
not included in the attachment. The following sub-element is associated with this element:
Name
0
maxOccurs:
minOccurs
maxOccurs
1
1
OriginalAttachmentFileName
1
Category
Simple
This element corresponds with the following item(s):
o
Part V. Suspicious Activity Report – Attachment
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Record this element when the FinCEN SAR includes an attachment containing tabular data (such as
transaction data) that provides additional suspicious activity information not suitable for inclusion in the
narrative; otherwise, do not record this element.
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Element Name:
ActivitySupportDocument
minOccurs:
0
maxOccurs:
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
1
FinCEN
SAR_Attachment.csv
Element Name:
OriginalAttachmentFileName
minOccurs:
1
maxOccurs:
1
Description:
Attachment file name (text). This element declares the attachment file name included with the FinCEN
SAR being filed. This element corresponds with the following item(s):
Part V. Suspicious Activity Report – Attachment (File name)
•
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivitySupportDocument
Element Restriction(s):
Required. This element must be recorded when the associated parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: Enter the attachment file name (e.g.
FinCEN SAR_Attachment_1.csv). The attachment file must be an MS Excel-compatible comma separated
value (CSV) file with a maximum size of 1 megabyte. Include the ".csv" extension at the end of the file
name.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded with a valid value but there is no corresponding attachment.
•
The batch submission contains an attachment but the
element of the associated FinCEN SAR within the batch XML is not recorded or the value is
null.
Remarks:
Example:
FinCEN SAR_Attachment.csv
4.6. Party Elements
Element Name:
Party
minOccurs:
6
maxOccurs:
1203
Description:
Party (header). This is the container for information about the individual or entity associated with the
FinCEN SAR (at the activity level); specifically, the transmitter [of the batch file], the transmitter contact,
the filing institution and contact office, the law enforcement contact agency and point of contact, the
financial institution where activity occurred, and the subject.
The following tables describe all possible sub-elements for each party type at the activity level:
Activity party type code definitions
35 = Transmitter | 37 = Transmitter Contact | 30 = Filing Institution | 8 = Contact Office
18 = LE Contact Agency | 19 = LE Contact Name |
34 = Financial Institution Where Activity Occurred | 33 = Subject
1.
Transmitter Information (Required | Batch Transmitter Information)
Name
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 35)
1
1
Simple
PartyName
1
1
Complex
Address
1
1
Complex
PhoneNumber
1
1
Complex
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Element Name:
Party
minOccurs:
PartyIdentification
2.
6
maxOccurs:
1
1
1203
Complex
Transmitter Contact Information (Required | Batch Transmitter Information)
Name
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 37)
1
1
Simple
PartyName
1
1
Complex
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 30)
1
1
Simple
PrimaryRegulatorTypeCode (Item 75)
1
1
Simple
PartyName (Items 76, 87)
1
2
Complex
Address (Items 82-86)
1
1
Complex
PartyIdentification (Items 77, 78, 81, 88)
1
3
Complex
OrganizationClassificationTypeSubtype (Items 79, 80)
1
15
Complex
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 8)
1
1
Simple
PartyName (Item 93)
1
1
Complex
PhoneNumber (Item 94)
1
1
Complex
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 18)
1
1
Simple
PartyName (Item 89)
1
1
Complex
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 19)
1
1
Simple
ContactDateText (Item 92)
0
1
Simple
PartyName (Item 90)
0
1
Complex
PhoneNumber (Item 91)
0
1
Complex
3.
Filing Institution (Required | FinCEN SAR Part IV, Items 75-82, 87)
Name
4.
Contact Office (Required | FinCEN SAR Part IV, Items 93-94)
Name
5.
LE Contact Agency (if available | FinCEN SAR Part IV, Item 89)
Name
6.
LE Contact Name (if available | FinCEN SAR Part IV, Items 90-92)
Name
7.
Financial Institution Where Activity Occurred (Required | FinCEN SAR Part III, Items 51-66, 69a,
68/69/70-74 if a Branch is involved)
Name
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 34)
1
1
Simple
LossToFinancialAmountText (Item 67)
0
1
Simple
NoBranchActivityInvolvedIndicator (Item 69a)
0
1
Simple
PayLocationIndicator (Item 56b)
0
1
Simple
PrimaryRegulatorTypeCode (Item 52)
1
1
Simple
SellingLocationIndicator (Item 56a)
0
1
Simple
SellingPayingLocationIndicator (Item 56c)
0
1
Simple
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Element Name:
Party
minOccurs:
6
maxOccurs:
1203
PartyName (Items 57, 58)
1
2
Complex
Address (Items 61-65)
1
1
Complex
PartyIdentification (Items 55, 59, 60, 66)
1
3
Complex
OrganizationClassificationTypeSubtype (Items 51, 53, 54)
1
12
Complex
PartyAssociation (Items 68, 69, 70-74)
0
1
Complex
minOccurs
maxOccurs
Content
ActivityPartyTypeCode
1
1
Simple
AdmissionConfessionNoIndicator (Item 23b)
0
1
Simple
AdmissionConfessionYesIndicator (Item 23a)
0
1
Simple
*AllCriticalSubjectInformationUnavailableIndicator(Item 3b)
0
1
Simple
BirthDateUnknownIndicator (Item 19a)
0
1
Simple
BothPurchaserSenderPayeeReceiveIndicator (Item 28c)
0
1
Simple
FemaleGenderIndicator (Item 8b)
0
1
Simple
IndividualBirthDateText (Item 19)
0
1
Simple
MaleGenderIndicator (Item 8a)
0
1
Simple
NoKnownAccountInvolvedIndicator (Item 27a)
0
1
Simple
PartyAsEntityOrganizationIndicator (Item 3a)
0
1
Simple
PayeeReceiverIndicator (Item 28b)
0
1
Simple
PurchaserSenderIndicator (Item 28a)
0
1
Simple
UnknownGenderIndicator (Item 8c)
0
1
Simple
*PartyName (Items 4-7, 9)
1
100
Complex
8.
Subject (Required | FinCEN SAR Part I, Items 3-28)
Name
*Address (Items 11-15)
1
99
Complex
PhoneNumber (Items 20, 21)
0
99
Complex
*PartyIdentification (Items 16-18)
2
100
Complex
PartyOccupationBusiness (Item 10)
0
1
Complex
ElectronicAddress (Item 22)
0
198
Complex
PartyAssociation (Items 24-26)
0
99
Complex
**PartyAccountAssociation (Items 27)
0
99
Complex
*In the event that all critical subject information is unavailable, the elements PartyName, Address, and
PartyIdentification become minOccurs “0” and should not be recorded; however, if the subject has one or
more known alternative names (which is not considered critical information), the PartyName element
would be recorded for each known subject alternative name (max 99).
**While Item 27 is associated with the subject, many of the elements associated with this item are reported
within the Financial Institution Where Account is Held (41) party type, which is nested within the Subject
(33) party type. Please refer to the Party Elements (Account Level) for more details.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Required. This element must be recorded.
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Element Name:
Party
minOccurs:
6
maxOccurs:
1203
The following table describes the minimum and maximum reporting requirements per FinCEN SAR
document by party type (at the activity level):
Party type
minOccurs
maxOccurs
Transmitter
1
1
Transmitter Contact
1
1
Filing Institution
1
1
Filing Institution Contact Office
1
1
Law Enforcement Agency
0
1
Law Enforcement Name
0
1
Financial Institution Where Activity Occurred
1
99
Subject
1
999
6
1104
Total (per document)
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or is incorrectly formatted.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
•
The following party types are not recorded or exceed the maximum occurrence for the
FinCEN SAR:
o
Transmitter (1 occurrence)
o
Transmitter Contact (1 occurrence)
o
Filing Institution (1 occurrence)
o
Designated Contact Office (1 occurrence)
o
Financial Institution Where Activity Occurred (no more than 99)
o
Subject (no more than 999)
•
One or both of the following party types are recorded more than once for the FinCEN SAR:
o
Law Enforcement Agency
o
Law Enforcement Name
Example:
See Part Elements by Party Type for detailed examples…
Element Name:
ActivityPartyTypeCode
Description:
Party type (code). This element identifies the type of party associated with the FinCEN SAR.
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for each element regardless of party type.
Value Restriction(s):
The value provided must adhere to the following requirements:
Code
Description
35
Transmitter
37
Transmitter Contact
30
Filing Institution
minOccurs:
8
Designated Contact Office
18
Law Enforcement Agency
19
Law Enforcement Name
34
Financial Institution Where Activity Occurred
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maxOccurs:
1
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Element Name:
ActivityPartyTypeCode
33
Remarks:
Example:
minOccurs:
1
maxOccurs:
1
Subject
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but with no value (i.e. the value is null).
•
The element contains an invalid value.
30
Element Name:
AdmissionConfessionNoIndicator
Description:
Corroborative statement to filer: No (indicator). This element declares that the subject individual has
made no corroborative statement to the filer. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
23b. Corroborative statement to filer (No)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the subject made no corroborative statement to the filer admitting to involvement in or otherwise
substantiating the suspicious activity; otherwise, do not record this element. Do not record this element
if the subject is an entity.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "No" to Corroborative
statement to filer)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
AdmissionConfessionYesIndicator
Description:
Corroborative statement to filer: Yes (indicator). This element declares that the subject individual has
made a statement to the filer admitting to involvement in or otherwise substantiating the suspicious
activity. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
23c. Corroborative statement to filer (Yes)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the subject has made a statement to the filer admitting to involvement in or otherwise
substantiating the suspicious activity; otherwise, do not record this element. Do not record this element
if the subject is an entity.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Yes" to Corroborative
statement to filer)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
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Element Name:
AllCriticalSubjectInformationUnavailableIndicator
Description:
All critical subject information unavailable (indicator). This element declares that all critical subject
information is unavailable. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
3b. Check if all critical* subject information is unavailable (does not include item *27)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and all critical* subject
information is unavailable with the exception of Item 27 “Financial Institution TIN and account
number(s) affected that are related to the subject”; otherwise, do not record this element.
*Refer to Attachment C (Item Instructions) to identify all critical items associated with the subject.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "All critical subject
information unavailable")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
BirthDateUnknownIndicator
Description:
Date of birth (date). This element identifies the date of birth associated with the subject. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
19a. Date of birth (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the date of birth is unknown*; otherwise, do not record this element.
*If the subject is an individual and the date of birth is known, record the
element with the birth date and do not record the element.
The value provided must adhere to the following requirements: "Y" (to indicate date of birth unknown)
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
BothPurchaserSenderPayeeReceiveIndicator
Description:
This element declares that the subject was both a purchaser/sender of the financial instrument(s) or
product(s) involved in the suspicious activity and payee/receiver of the instrument(s) or product(s)
involved in the suspicious activity. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
28c. Subject’s role in suspicious activity (both Purchaser/Sender and Payee/Receiver)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
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Element Name:
BothPurchaserSenderPayeeReceiveIndicator
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject was both
the payee/receiver and purchaser/sender of the instrument(s) or product(s) involved in the suspicious
activity; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: "Y" (to indicate both Purchaser/Sender
and Payee/Receiver)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
More than one role is recorded for the Subject.
Y
Element Name:
ContactDateText
Description:
Law enforcement contact date (date). This element identifies the most-recent date the law enforcement
agency was contacted about the suspicious activity. This element corresponds with the following
item(s):
•
minOccurs:
0
maxOccurs:
1
92. LE contact date
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the LE Contact Name (19) and the mostrecent date the law enforcement agency was contacted about the suspicious activity is available;
otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded for the element is not in the required format (YYYYMMDD).
20171105
Element Name:
FemaleGenderIndicator
Description:
Gender: Female (indicator). This element declares that the gender of the subject is female. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
8b. Gender (female)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is female; if the subject's gender is male or unknown, or the subject is an entity, do
not record this element.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: "Y" (to indicate female gender)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
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Element Name:
FemaleGenderIndicator
minOccurs:
0
Example:
Y
maxOccurs:
1
maxOccurs:
1
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one gender is recorded for the Subject.
•
The gender is specified for the entity Subject.
Element Name:
IndividualBirthDateText
Description:
Date of birth unknown (indicator). This element declares that the date of birth associated with the
subject is unknown. This element corresponds with the following item(s):
•
minOccurs:
0
19. Date of birth
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the date of birth is known*; otherwise, do not record this element.
*If the subject is an individual and the date of birth is unknown, record the
element with a "Y" value and do not record the
element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. 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 19780200. Do
not enter zeros for the year if the year is unknown.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (YYYYMMDD).
•
The element is not recorded for the individual Subject and both
or do not
contain a “Y” value.
•
The date of birth recorded is less than January 1, 1900.
19801025
Element Name:
LossToFinancialAmountText
Description:
Loss to financial institution (amount). This element identifies the dollar amount loss to the financial
institution because of the suspicious activity. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
67. Loss to financial institution (if applicable)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Financial institution where activity
occurred (34) and the institution has suffered a loss as a result of the suspicious activity; otherwise, do
not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: 1-15 numeric characters (without
leading zeros) denominated in whole U.S. Dollars. The amount entered in this element cannot be zero
and cannot be greater than the amount recorded in the element. Do not
include non-numeric characters.
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Element Name:
Remarks:
Example:
LossToFinancialAmountText
minOccurs:
0
maxOccurs:
1
NOTE: 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 activity report, enter in the
element the loss amount for the current FinCEN SAR and record in the
narrative the total aggregated losses for all FinCEN SARs filed on the suspicious activity.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The amount recorded contains one or more non-numeric characters.
•
The amount recorded is equal to zero.
•
The amount recorded is greater than the amount involved in the report.
15000
Element Name:
MaleGenderIndicator
Description:
Gender: Male (indicator). This element declares that the gender of the subject is male. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
8a. Gender (male)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is male; if the subject's gender is female or unknown, or the subject is an entity, do
not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate male gender)
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one gender is recorded for the Subject.
•
The gender is not specified for the individual Subject.
•
The gender “male” is specified for the entity Subject.
Y
Element Name:
NoBranchActivityInvolvedIndicator
Description:
No branch involved (indicator). This element declares that there is no branch location involved in the
suspicious activity for the associated financial institution where activity occurred. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
69a. No branch activity involved
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and no branch was involved in the suspicious activity (or the branch country is unknown);
otherwise, do not record this element. If this element is recorded, do not record a party type associated
with the Branch Where Activity Occurred (46) for the associated Financial Institution (34).
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate "No branch activity
involved")
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Element Name:
Remarks:
Example:
NoBranchActivityInvolvedIndicator
minOccurs:
0
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
This element is recorded with a “Y” value for the Financial institution (34) but one or more
Branch (46) party type locations are also recorded.
•
The party type associated with the branch where activity occurred is not recorded and "no
branch activity involved" is not indicated.
Y
Element Name:
NoKnownAccountInvolvedIndicator
Description:
No known account involved (indicator). This element declares that no account related to the subject is
involved in the suspicious activity. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
27a. No known account involved
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and no account related to
the subject is involved in the suspicious activity; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "No known account
involved")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a “Y” value and the element is also
recorded.
•
The element is not recorded and the Y
Element Name:
PartyAsEntityOrganizationIndicator
Description:
Entity (indicator). This element declares that the subject is an entity. This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
3a. Check if entity
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject is an entity;
otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate that the subject is an
entity)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
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Element Name:
PayeeReceiverIndicator
Description:
Payee/Receiver (indicator). This element declares that the subject was the payee or receiver of the
instrument(s) or product(s). This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
28b. Subject’s role in suspicious activity (Payee/Receiver)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject was the
payee or receiver of the instrument(s) or product(s) involved in the suspicious activity; otherwise, do not
record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Payee/Receiver)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
More than one role is recorded for the Subject.
Y
Element Name:
PayLocationIndicator
Description:
Paying location (indicator). This element declares that the customer received payment from the financial
institution where activity occurred for the products or instruments recorded in the FinCEN SAR. This
element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
56b. Financial institution’s role in transaction (Paying location)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the customer received payment from the Financial Institution (34) for the recorded
products or instruments; otherwise, do not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate "Paying location")
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
PrimaryRegulatorTypeCode
minOccurs:
0
maxOccurs:
1
Description:
Primary regulator type (code). This element identifies the primary federal regulator or BSA examiner of
the financial institution where activity occurred as well as the filing institution. This element corresponds
with the following item(s):
•
Financial Institution Where Activity Occurred: 52. Primary Federal Regulator
•
Filing Institution: 75. Primary Federal Regulator
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
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Element Name:
PrimaryRegulatorTypeCode
Element Restriction(s):
Conditionally Required. This element must be recorded for the following party types; otherwise, do not
record this element:
•
Financial Institution Where Activity Occurred (34)
•
Filing Institution (30)
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements:
Code
Description
9
CFTC (Commodities Futures Trading Commission)
1
Federal Reserve
2
FDIC (Federal Deposit Insurance Corporation)
13
FHFA (Federal Housing Finance Agency)
7
IRS (Internal Revenue Service)
3
NCUA (National Credit Union Administration)
4
OCC (Office of the Comptroller of the Currency)
6
SEC (Securities and Exchange Commission)
99
Not Applicable
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is not recorded for the approved party type (see Element Restrictions for more
information).
•
The element is recorded but with no value (i.e. the value is null).
•
The element contains an invalid value.
4
Element Name:
PurchaserSenderIndicator
Description:
Purchaser/Sender (indicator). This element declares that the subject purchased or sent the financial
instrument(s) or product(s) involved in the suspicious activity. This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
28a. Subject’s role in suspicious activity (Purchaser/Sender)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject purchased
or sent the financial instrument(s) or product(s) involved in the suspicious activity; otherwise, do not
record this element.
The value provided must adhere to the following requirements: "Y" (to indicate Purchaser/Sender)
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
More than one role is recorded for the Subject.
Y
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Element Name:
SellingLocationIndicator
Description:
Selling location (indicator). This element declares that the customer purchased at the financial
institution where activity occurred the products or instruments recorded in the FinCEN SAR. This
element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
56a. Financial Institution’s role in transaction: Selling location
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the customer purchased at the financial institution (34) the recorded products or
instruments; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Selling location")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
SellingPayingLocationIndicator
Description:
Selling and Paying location (indicator). This element declares that the financial institution where activity
occurred was both a paying and selling location for the products or instruments recorded in the FinCEN
SAR. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
56c. Financial Institution’s role in transaction: Both Selling and Paying location
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the financial institution was both the selling and paying location for the recorded
products or instruments; otherwise, do not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate both Selling and Paying
location)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Value Restriction(s):
Remarks:
Example:
Y
Element Name:
UnknownGenderIndicator
Description:
Gender: Unknown (indicator). This element declares that the gender of the subject is unknown. This
element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
8c. Gender (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is unknown; if the subject's gender is known, or the subject is an entity, do not
record this element.
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Element Name:
UnknownGenderIndicator
minOccurs:
0
maxOccurs:
1
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate unknown gender)
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one gender is recorded for the Subject.
•
The gender is not specified for the individual Subject.
•
The gender “unknown” is specified for the entity Subject.
Example:
Y
Element Name:
PartyName
See PartyName Elements for details.
Element Name:
Address
See Address Elements for details.
Element Name:
PhoneNumber
See PhoneNumber Elements for details.
Element Name:
PartyIdentification
See PartyIdentification Elements for details.
Element Name:
OrganizationClassificationTypeSubtype
See OrganizationClassificationTypeSubtype Elements for details.
Element Name:
PartyOccupationBusiness
See PartyOccupationBusiness Elements for details.
Element Name:
ElectronicAddress
See ElectronicAddress Elements for details.
Element Name:
PartyAssociation
See PartyAssociation Elements for details.
Element Name:
PartyAccountAssociation
See PartyAccountAssociation Elements for details.
4.6.1. PartyName Elements
Element Name:
PartyName
minOccurs:
Description:
Party name (header). This is the container for information about the name of the party. The party name
can be a legal name, doing business as (DBA) name, or also known as (AKA) name depending on the
party type identified.
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0
maxOccurs:
100
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Element Name:
PartyName
minOccurs:
0
maxOccurs:
The following sub-element is associated with this element:
100
Activity party type code definitions
35 = Transmitter | 37 = Transmitter Contact | 30 = Filing Institution | 8 = Contact Office
18 = LE Contact Agency | 19 = LE Contact Name |
34 = Financial Institution Where Activity Occurred | 33 = Subject
1.
Transmitter Information: Legal name (Required)
Name
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName
1
1
Simple
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName
1
1
Simple
maxOccurs
Content
2.
Transmitter Contact Information: Legal name (Required)
Name
3.
Filing Institution Information:
a.
Legal name (Required | FinCEN SAR Part IV, Items 76)
Name
minOccurs
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName (Item 76)
1
1
Simple
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code AKA or DBA)
1
1
Simple
RawPartyFullName (Item 87)
1
1
Simple
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName (Item 93)
1
1
Simple
b.
Alternate name (if applicable | FinCEN SAR Part IV, Item 87)
Name
4.
Contact Office: Legal name (Required | FinCEN SAR Part IV, Items 93)
Name
5.
LE Contact Agency: Legal name (if applicable | FinCEN SAR Part IV, Item 89)
Name
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName (Item 89)
1
1
Simple
6.
LE Contact Name: Legal name (if applicable | FinCEN SAR Part IV, Items 90)
Name
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName (Item 90)
1
1
Simple
7.
Financial Institution Where Activity Occurred:
a.
Legal name/unknown (Required | FinCEN SAR Part III, Item 57)
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Element Name:
PartyName
minOccurs:
0
Name
maxOccurs:
100
minOccurs
maxOccurs
Content
EntityLastNameUnknownIndicator (Code Y)
0
1
Simple
PartyNameTypeCode (Code L)
1
1
Simple
RawPartyFullName (Item 57)
0
1
Simple
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code AKA or DBA)
1
1
Simple
RawPartyFullName (Item 58)
1
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded.
b.
Alternate name (if applicable | FinCEN SAR Part III, Item 58)
Name
8.
Subject
a.
Legal name/unknown (Conditionally Required | FinCEN SAR Part I, Items 4-7)
Name
minOccurs
maxOccurs
Content
EntityLastNameUnknownIndicator (Item 4a)
0
1
Simple
FirstNameUnknownIndicator (Item 5a)
0
1
Simple
PartyNameTypeCode (Code L)
1
1
Simple
RawEntityIndividualLastName (Item 4)
0
1
Simple
RawIndividualFirstName (Item 5)
0
1
Simple
RawIndividualMiddleName (Item 6)
0
1
Simple
RawIndividualNameSuffixText (Item 7)
0
1
Simple
minOccurs
maxOccurs
Content
PartyNameTypeCode (Code AKA or DBA)
1
1
Simple
RawPartyFullName (Item 58)
1
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded. In the event that all critical subject
information is unavailable, do not record the element for the Subject (33) unless recording
the subjects alternative name (if known).
b.
Alternate name (if applicable | FinCEN SAR Part I, Item 9)
Name
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for all party types (Activity Level) with the following exception:
•
In the event that all critical subject information is unavailable, do not record this element for
the Subject (33) unless recording the subject’s alternative name (if known).
The following table describes the minimum and maximum reporting requirements per party type (at the
activity level):
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Element Name:
PartyName
minOccurs:
Party type
0
Legal
maxOccurs:
100
Alternate
(min-max)
(min-max)
Transmitter
1-1
n/a
Transmitter Contact
1-1
n/a
Filing Institution
1-1
0-1
Filing Institution Contact Office
1-1
n/a
Law Enforcement Agency
0-1
n/a
Law Enforcement Name
0-1
n/a
Financial Institution Where Activity Occurred
1-1
0-99
Subject*
0-1
0-99
*In the event that all critical subject information is unavailable, do not record the element
for the Subject (33) unless recording the subjects alternative name (if known).
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded for the Subject (33) legal name and
does not contain a “Y” value.
•
More than one legal name is recorded for a party within a single FinCEN SAR Activity.
Example:
Y
L
Mann
Randy
Junior
Element Name:
EntityLastNameUnknownIndicator
Description:
Entity name or Individual last name unknown (indicator). This element declares that the person legal
name (if entity) or last name (if individual) is unknown. This element corresponds with the following
item(s):
•
•
minOccurs:
0
maxOccurs:
1
Subject: 4a. Individual’s last name or entity’s legal name (unknown)
Financial Institution Where Activity Occurred: 57a. Legal name of Financial Institution
(unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
•
Subject (33), the is "L" (legal), and the legal entity/last name of the
subject is unknown.
•
Financial institution where activity occurred (34), the is "L" (legal),
and the institution legal name (entity or individual) is unknown.
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate entity/last name
unknown)
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Element Name:
Remarks:
Example:
EntityLastNameUnknownIndicator
minOccurs:
0
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
FirstNameUnknownIndicator
Description:
Individual first name unknown (indicator). This element declares that the first name of the subject is
unknown. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
5a. First name (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Conditionally Required. Record this element for the Subject (33) party type when the
is "L" (legal) and the first name of the subject is unknown; otherwise, do not
record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate first name unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
PartyNameTypeCode
Description:
Party name type (code). This element identifies the type of name recorded for the party; specifically,
legal name, doing business as (DBA) name, or also known as (AKA) name. This element corresponds
with the following item(s):
•
•
•
•
•
minOccurs:
1
maxOccurs:
1
Transmitter
o
Name (legal)
Transmitter Contact
o
Name (legal)
Filing Institution
o
76. Filer name (legal)
o
87. Alternate name (dba/aka)
o
89. LE contact agency (legal)
o
90. LE contact name (legal)
o
93. Designated contact office (legal)
Financial Institution Where Activity Occurred
o
57. Legal name of financial institution (legal)
o
58. Alternate name (dba/aka)
Subject:
o
4. Individual’s last name or entity’s legal name (legal)
o
9. Alternate name (dba/aka)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: Identify the party name type by
recording the appropriate code from the list below:
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Element Name:
PartyNameTypeCode
Code
Example:
1
maxOccurs:
1
Description
L
Remarks:
minOccurs:
Legal
DBA
Doing Business As*
AKA
Also Known As*
*DBA and AKA name types may only be used for the following party types:
•
Filing Institution (30)
•
Financial Institution Where Activity Occurred (34)
•
Subject (33)
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but with no value (i.e. the value is null).
•
The element contains an invalid value.
•
The element is recorded with a value that is not approved for the associated party type (see
Value Restrictions for more information).
L
Element Name:
RawEntityIndividualLastName
Description:
Entity name or Individual last name (text). This element identifies the subject's legal name, whether it be
the legal name of the entity or the last name of the individual. This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
4. Individual’s last name or entity’s legal name
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Conditionally Required. Record this element when the party type is associated with the Subject (33), the
is "L" (legal), and the entity/last name of the subject is known*; otherwise, do
not record this element.
*If the entity/last name of the subject is unknown, record the
element with the value “Y” and do not record the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 150 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the Subject and unknown is not
indicated.
Mann
Element Name:
RawIndividualFirstName
Description:
Individual first name (text). This element identifies the first name of the subject. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
5. First name
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
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Element Name:
RawIndividualFirstName
Element Restriction(s):
Conditionally Required. Record this element when the party type is associated with the Subject (33), the
is "L" (legal), the subject is an individual, and the first name is known*;
otherwise, do not record this element.
*If the subject is an individual and the first name is unknown, record the
with the value “Y” and do not record the following elements:
•
•
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: 35 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for an individual Subject and
unknown is not indicated.
Will
Element Name:
RawIndividualMiddleName
Description:
Individual middle name (text). This element identifies the middle name of the subject. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
6. Middle name
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the
is "L" (legal), the subject is an individual, and the middle name is known*;
otherwise, do not record this element.
*If the subject is an individual and the middle name is unknown, this element (along with the
element) should not be recorded.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 35 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
Randy
Element Name:
RawIndividualNameSuffixText
Description:
Individual suffix name (text). This element identifies the suffix name of the subject. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
7. Suffix
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Record this element when the party type is associated with the Subject (33), the
is "L" (legal), the subject is an individual, and the suffix name is known*;
otherwise, do not record this element.
*If the subject is an individual and the suffix name is unknown, this element (along with the
element) should not be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 35 characters or less
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Element Name:
Remarks:
Example:
RawIndividualNameSuffixText
minOccurs:
0
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
Junior
Element Name:
RawPartyFullName
Description:
Party full name (text). This element identifies the full name of the party, whether it be the legal name if
the institution, or DBA/AKA name of the institution or individual. This element corresponds with the
following item(s):
•
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter
o
Name (legal)
Transmitter Contact
o
Name (legal)
Filing Institution
o
76. Filer name (legal)
o
87. Alternate name (dba/aka)
o
89. LE contact agency (legal)
o
90. LE contact name (legal)
o
93. Designated contact office (legal)
Financial Institution Where Activity Occurred
o
57. Legal name of financial institution (legal)
o
58. Alternate name (dba/aka)
Subject:
o
9. Alternate name (dba/aka)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyName
Element Restriction(s):
Conditionally Required. Record this element for the following party types and conditions:
•
The PartyNameTypeCode is “L” (legal) and the party type is associated with:
o
Transmitter (35)
o
Transmitter Contact (37) (NOTE: The value recorded must be the name of the
individual to be contacted on issues involving the batch file. This entry must be the
same for all FinCEN SARs in the batch file.)
o
Filing Institution (30)
o
Designated Contact Office (8) (NOTE: This value recorded must be the title of the
administrative office (such as Compliance Office) that should be contacted for
additional information about the FinCEN SAR.)
o
LE Contact Agency (18)
o
LE Contact Name (19)
o
Financial Institution Where Activity Occurred (34) and the legal name is known. If
the Financial Institution (34) legal name is unknown, record the
element with the value “Y” and do not record
the element.
•
The PartyNameTypeCode is “DBA” or "AKA" and the party type is associated with:
o
Filing institution* (30)
o
Financial Institution Where Activity Occurred* (34)
o
Subject* (33)
*If there is no DBA or AKA name for the above party types, only record the element
associated with the legal name.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: 150 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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Element Name:
RawPartyFullName
minOccurs:
0
maxOccurs:
1
The element is not recorded for the financial institution where activity occurred legal name
and unknown is not indicated.
•
The element is not recorded with a value for the designated contact office.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a value for the financial institution where activity occurred legal
name and unknown is indicated.
•
The element is not recorded for the filing institution.
•
Example:
L
Union Bank of California
4.6.2. Address Elements
Element Name:
Address
minOccurs:
0
maxOccurs:
Description:
Address (header). This is the container for information about the address of the party.
99
The following sub-element is associated with this element:
Activity party type code definitions
35 = Transmitter | 30 = Filing Institution
34 = Financial Institution Where Activity Occurred | 33 = Subject
1.
Transmitter Information: Address (Required)
Name
minOccurs
maxOccurs
Content
RawCityText
1
1
Simple
RawCountryCodeText
1
1
Simple
RawStateCodeText
1
1
Simple
RawStreetAddress1Text
1
1
Simple
RawZIPCode
1
1
Simple
2.
Filing Institution Information: Address (Required | FinCEN SAR Part IV, Items 82-86)
Name
minOccurs
maxOccurs
Content
RawCityText (Item 83)
1
1
Simple
RawCountryCodeText (Item 86)
1
1
Simple
RawStateCodeText (Item 84)
1
1
Simple
RawStreetAddress1Text (Item 82)
1
1
Simple
RawZIPCode (Item 85)
1
1
Simple
3.
Financial Institution Where Activity Occurred: Address/Unknown (Required | FinCEN SAR Part
III, Items 61-65)
Name
minOccurs
maxOccurs
Content
CityUnknownIndicator (Item 62a)
0
1
Simple
CountryCodeUnknownIndicator (Item 65a)
0
1
Simple
RawCityText (Item 62)
0
1
Simple
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Element Name:
Address
minOccurs:
0
maxOccurs:
99
RawCountryCodeText (Item 65)
0
1
Simple
RawStateCodeText (Item 63)
0
1
Simple
RawStreetAddress1Text (Item 61)
0
1
Simple
RawZIPCode (Item 64)
0
1
Simple
StreetAddressUnknownIndicator (Item 61a)
0
1
Simple
ZIPCodeUnknownIndicator (Item 64a)
0
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded.
4.
Subject: Address/Unknown* (Conditionally Required | FinCEN SAR Part I, Items 11-15)
Name
minOccurs
maxOccurs
Content
CityUnknownIndicator (Item 12a)
0
1
Simple
CountryCodeUnknownIndicator (Item 15a)
0
1
Simple
RawCityText (Item 12)
0
1
Simple
RawCountryCodeText (Item 15)
0
1
Simple
RawStateCodeText (Item 13)
0
1
Simple
RawStreetAddress1Text (Item 11)
0
1
Simple
RawZIPCode (Item 14)
0
1
Simple
StateCodeUnknownIndicator (Item 13a)
0
1
Simple
StreetAddressUnknownIndicator (Item 11a)
0
1
Simple
ZIPCodeUnknownIndicator (Item 14a)
0
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded. In the event that all critical subject
information is unavailable, do not record the element for the Subject (33).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for the following party types (activity level):
Party type
Address
(min-max)
Transmitter
1-1
Filing Institution
1-1
Financial Institution Where Activity Occurred
1-1
Subject*
0-99
*In the event that all critical subject information is unavailable, do not record the element for
the Subject (33).
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
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Element Name:
Address
minOccurs:
0
maxOccurs:
Example:
Y
US
VA
987 Rocky Road
87598
99
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded for the subject address and
does not contain a “Y” value.
•
The element is recorded for the subject address and
contains a “Y” value.
Element Name:
CityUnknownIndicator
Description:
City unknown (indicator). This element declares that the city associated with the address of the party is
unknown. This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
12a. City (unknown): Subject
62a. City (unknown): Financial Institution Where Activity Occurred
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element when the city is unknown* for the following party types:
•
Financial institution where activity occurred (34)
•
Subject (33)
*If the city is known, record the element with city name and do not record the
element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate city unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
CountryCodeUnknownIndicator
Description:
Country unknown (indicator). This element declares that country associated with the address of the
party is unknown. This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
15a. Country Code (unknown): Subject
65a. Country Code (unknown): Financial Institution Where Activity Occurred
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element when the country is unknown* for the following party
types:
•
Financial institution where activity occurred (34)
•
Subject (33)
*If the country is known, record the element with the ISO 3166-2 country code
and do not record the element.
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate country unknown)
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Element Name:
Remarks:
Example:
CountryCodeUnknownIndicator
minOccurs:
0
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
RawCityText
Description:
City (text). This element identifies the city associated with the address of the party. This element
corresponds with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter: City
Subject: 12. City
Financial Institution Where Activity Occurred: 62. City
Filing Institution: 83. City
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Required. This element must be recorded for the following party types:
•
Transmitter (35)
•
Filing institution (30)
Conditionally Required. Record this element when the city is known* for the following party types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the city is unknown, record the element with the value “Y” and do not
record the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 50 characters or less.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
•
The element is not recorded or does not contain a value for the transmitter or filing
institution.
Tysons Corner
Element Name:
RawCountryCodeText
Description:
Country (code). This element identifies the country associated with the party. This element corresponds
with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter: Country Code
Subject: 15. Country Code
Financial Institution Where Activity Occurred: 65. Country Code
Filing Institution: 86. Country Code
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Required. This element must be recorded for the following party types:
•
Transmitter (35)
•
Filing institution (30)
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Element Name:
RawCountryCodeText
Value Restriction(s):
The value provided must adhere to the following requirements: Country codes (including U.S. Territory
codes) must adhere to the two-letter country codes found in ISO 3166-2.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not a valid country code.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the transmitter or filing
institution.
•
The element is not recorded or does not contains a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
•
State code and country code mismatch when U.S. Territory is recorded.
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
Conditionally Required. Record this element when the country is known* for the following party types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the country is unknown, record the element with the value “Y”
and do not record the element.
US
Element Name:
RawStateCodeText
Description:
State/Territory/Province (code). This element identifies the state/territory/province associated with the
address of the party when the corresponding country is equal to US (United States), CA (Canada), MX
(Mexico), or a U.S. Territory. This element corresponds with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter: State
Subject: 13. State
Financial Institution Where Activity Occurred: 63. State
Filing Institution: 84. State
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element for the following party types when the corresponding
country is US (United States), CA (Canada), MX (Mexico), or a U.S. Territory*; otherwise, do not record
this element:
•
Transmitter (35)
•
Filing institution (30)
•
Subject (33) and the state is known**
•
Financial institution where activity occurred (34)
*If the country is a U.S. Territory, record the same U.S. Territory code for the state.
**If the subject's state is unknown, record the element with the value
“Y” and do not record the element.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not a valid state code.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the transmitter or filing
institution when the country is US, CA, MX, or a U.S. Territory.
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Element Name:
RawStateCodeText
•
•
•
minOccurs:
0
maxOccurs:
1
0
maxOccurs:
1
The element is not recorded or does not contains a value for the subject or the financial
institution where activity occurred when the country is US, CA, or MX, and unknown is not
indicated.
The element contains a value and the country is not US, CA, MX, or a U.S. Territory.
State code and country code mismatch when U.S. Territory is recorded.
Example:
VA
Element Name:
RawStreetAddress1Text
Description:
Street address (text). This element identifies the street address of the party. This element corresponds
with the following item(s):
•
•
•
•
minOccurs:
Transmitter: Street Address
Subject: 11. Street Address
Financial Institution Where Activity Occurred: 61. Street Address
Filing Institution: 82. Street Address
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Required. This element must be recorded for the following party types:
•
Transmitter (35)
•
Filing institution (30)
Conditionally Required. Record this element when the street address is known* for the following party
types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the street address is unknown, record the element with the value
“Y” and do not record the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 100 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
•
The element is not recorded or does not contain a value for the transmitter or filing
institution.
987 Rocky Road
Element Name:
RawZIPCode
Description:
ZIP/Postal Code (text). This element identifies the ZIP Code or foreign postal code associated with the
address of the party. This element corresponds with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter: ZIP/Postal Code
Subject: 14. ZIP/Postal Code
Financial Institution Where Activity Occurred: 64. ZIP/Postal Code
Filing Institution: 85. ZIP/Postal Code
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Required. This element must be recorded for the following party types:
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Element Name:
Value Restriction(s):
Remarks:
Example:
RawZIPCode
minOccurs:
0
maxOccurs:
1
•
Transmitter (35)
•
Filing institution (30)
Conditionally Required. Record this element when the ZIP/Postal Code is known* for the following party
types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the ZIP/Postal Code is unknown, record the element with the value “Y”
and do not record the element.
The value provided must adhere to the following requirements: For a U.S. address (including U.S.
Territories): 5 or 9 numeric character entry; 9 numeric character entry cannot end with four zeros or four
nines. For a non-U.S. address: 9 (or less) character entry. Do not include punctuation or formatting such
as hyphens, periods, and spaces within the value entry
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded contains punctuation or formatting.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
•
The element is not recorded or does not contain a value for the transmitter or filing
institution.
•
The value recorded is not equal to 5 or 9 numeric characters, is a 9-digit value ending in four
zeros or four nines, and the corresponding country is equal to US or a U.S. Territory code.
87598
Element Name:
StateCodeUnknownIndicator
Description:
State unknown (indicator). This element declares that state associated with the address of the party is
unknown when the corresponding country is equal to US (United States), CA (Canada), or MX (Mexico).
This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
13a. State (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element for the Subject (33) party type when the state is unknown*
and the corresponding country is US (United States), CA (Canada), or MX (Mexico); otherwise, do not
record this element.
*If the subject's state is known, record the element with ISO 3166-2 state code
and do not record the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate state unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
StreetAddressUnknownIndicator
Description:
Street address unknown (indicator). This element declares that the street address of the party is
unknown. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
Subject: 11a. Address (unknown)
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Element Name:
StreetAddressUnknownIndicator
•
minOccurs:
0
maxOccurs:
Financial Institution Where Activity Occurred: 61a. Address (unknown)
1
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element when the street address is unknown* for the following
party types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the street address is known, record the element with street address and
do not record the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate street address unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
ZIPCodeUnknownIndicator
Description:
ZIP/Postal Code unknown (indicator). This element declares that the ZIP Code or foreign postal code
associated with the address of the party is unknown. This element corresponds with the following
item(s):
•
•
minOccurs:
0
maxOccurs:
1
Subject: 14a. ZIP/Postal Code (unknown)
Financial Institution Where Activity Occurred: 64a. ZIP/Postal Code (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Conditionally Required. Record this element when the ZIP/Postal Code is unknown* for the following
party types:
•
Subject (33)
•
Financial institution where activity occurred (34)
*If the ZIP/Postal Code is known, record the element with the code and do not record
the element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate ZIP/Postal code
unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
4.6.3. PhoneNumber Elements
Element Name:
PhoneNumber
minOccurs:
Description:
Telephone number (header). This is the container for information about the telephone number of the
party.
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0
maxOccurs:
99
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Element Name:
PhoneNumber
minOccurs:
0
maxOccurs:
The following sub-element is associated with this element:
99
Activity party type code definitions
35 = Transmitter | 8 = Contact Office
19 = LE Contact Name | 33 = Subject
1.
Transmitter Information: Telephone (Required)
Name
minOccurs
maxOccurs
Content
1
1
Simple
minOccurs
maxOccurs
Content
PhoneNumberExtensionText (Item 94a)
0
1
Simple
PhoneNumberText (Item 94)
1
1
Simple
minOccurs
maxOccurs
Content
PhoneNumberExtensionText (Item 91a)
0
1
Simple
PhoneNumberText (Item 91)
0
1
Simple
minOccurs
maxOccurs
Content
PhoneNumberExtensionText (Item 21a)
0
1
Simple
PhoneNumberText (Item 21)
0
1
Simple
PhoneNumberTypeCode (Item 20)
0
1
Simple
PhoneNumberText
2.
Contact Office: Telephone (Required | FinCEN SAR Part IV, Item 94)
Name
3.
LE Contact Name: Telephone (If applicable | FinCEN SAR Part IV, Item 91)
Name
4.
Subject: Telephone (If available | FinCEN SAR Part I, Item 21)
Name
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for the following party types (activity level):
Party type
Telephone
Transmitter
1-1
Contact Office
1-1
(min-max)
LE Contact Name
0-1
Subject
0-99
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
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Element Name:
PhoneNumber
Example:
5584
6194760276
R
Element Name:
PhoneNumberExtensionText
Description:
Telephone extension (text). This element identifies the telephone extension associated with the
telephone number of the party (if known). This element corresponds with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
The element contains a “SeqNum” attribute with a duplicate or invalid value.
minOccurs:
0
maxOccurs:
99
1
Subject: 21a. Phone number extension (if any)
LE Contact Name: 91a. LE contact phone number extension (if any)
Contact Office: 94a. Designated contact office phone number extension (if any)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PhoneNumber
Element Restriction(s):
Record this element when the telephone number extension is known for the following party types;
otherwise, do not record this element:
•
Subject (33)
•
LE Contact Name (19)
•
Contact Office (8)
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 6 numeric characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
5584
Element Name:
PhoneNumberText
Description:
Telephone number (text). This element identifies the telephone number of the party. This element
corresponds with the following item(s):
•
•
•
•
minOccurs:
0
maxOccurs:
1
Transmitter: Phone number
Subject: 21. Phone number
LE Contact Name: 91. LE contact phone number
Contact Office: 94. Designated contact office phone number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PhoneNumber
Element Restriction(s):
Record this element for the following party types and circumstances; otherwise, do not record this
element:
•
Transmitter (35)Contact Office (8)
•
Subject (33) and the telephone number is known
•
LE Contact Name (19) and the telephone number is known
Value Restriction(s):
The value provided must adhere to the following requirements by party type:
•
Transmitter (35)
o
10 numeric characters; not all same digit (such as all 0’s or all 9’s). NOTE: This
number must be the same for all FinCEN SARs in the batch file.
•
Contact Office (8) / Subject (3) / LE Contact Name (19)
o
16 numeric characters or less; not all same digit (such as all 0’s or all 9’s)
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Element Name:
Remarks:
Example:
PhoneNumberText
minOccurs:
0
maxOccurs:
1
maxOccurs:
1
Do not include punctuation or formatting such as hyphens, periods, and spaces within the value entry
regardless of party type.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the designated contact office.
6194760276
Element Name:
PhoneNumberTypeCode
Description:
Telephone number type (code). This element identifies the telephone number type associated with the
subject. This element corresponds with the following item(s):
•
minOccurs:
0
20. Phone number – type
o
a. Home
o
b. Work
o
c. Mobile
o
d. Fax
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PhoneNumber
Element Restriction(s):
Record this element for the Subject (33) party type when a phone number is recorded with the
element; otherwise, do not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: Identify the phone number type by
recording the appropriate code from the list below:
Code
Remarks:
Example:
Description
R
Residence (Home)
W
Work
M
Mobile
F
Fax
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is an invalid code.
R
4.6.4. PartyIdentification Elements
Element Name:
PartyIdentification
Description:
minOccurs:
0
maxOccurs:
100
Party identification (header). This is the container for information about the identification associated
with the party.
The following sub-element is associated with this element:
Activity party type code definitions
35 = Transmitter | 30 = Filing Institution
34 = Financial Institution Where Activity Occurred | 33 = Subject
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Element Name:
PartyIdentification
1.
minOccurs:
0
maxOccurs:
100
Transmitter Information
a.
Transmitter Control Code (TCC) (Required)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText
1
1
Simple
PartyIdentificationTypeCode (Code 28)
1
1
Simple
minOccurs
maxOccurs
Content
PartyIdentificationNumberText
1
1
Simple
PartyIdentificationTypeCode (Code 4)
1
1
Simple
b.
Taxpayer Identification Number (TIN) (Required)
Name
2.
Filing Institution
a.
TIN (EIN, SSN/ITIN, Foreign) (Required | FinCEN SAR Part IV, Item 77-78)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 77)
1
1
Simple
PartyIdentificationTypeCode (Item 78)
1
1
Simple
b.
Filing institution identification (CRD, IARD, etc.) (if applicable | FinCEN SAR Part IV,
Item 81)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 81)
1
1
Simple
PartyIdentificationTypeCode (Item 81)
1
1
Simple
c.
Internal control/file number (if available | FinCEN SAR Part IV, Item 88)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 88)
1
1
Simple
PartyIdentificationTypeCode (Code 29)
1
1
Simple
3.
Financial Institution Where Activity Occurred
a.
TIN (EIN, SSN/ITIN, Foreign) (Required | FinCEN SAR Part III, Item 59-60)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 59)
0
1
Simple
PartyIdentificationTypeCode (Item 60)
1
1
Simple
TINUnknownIndicator (Item 59a)
0
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded.
b.
Financial institution identification (CRD, IARD, etc.) (if applicable | FinCEN SAR Part
III, Item 55)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 55)
1
1
Simple
PartyIdentificationTypeCode (Item 55)
1
1
Simple
c.
Internal control/file number (if available | FinCEN SAR Part III, Item 66)
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Element Name:
PartyIdentification
minOccurs:
0
Name
maxOccurs:
100
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 66)
1
1
Simple
PartyIdentificationTypeCode (Code 29)
1
1
Simple
4.
Subject
a.
TIN/Unknown* (EIN, SSN/ITIN, Foreign) (Conditionally Required | FinCEN SAR Part I,
Item 16-17)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 16)
0
1
Simple
PartyIdentificationTypeCode (Item 17)
1
1
Simple
TINUnknownIndicator (Item 16a)
0
1
Simple
*If unknown is indicated, the corresponding element whose value is unknown should not be recorded;
otherwise, the unknown indicator element should not be recorded.
b.
Form of identification/Unknown* (Driver’s license, Passport, etc.) (Conditionally
Required | FinCEN SAR Part I, Item 18)
Name
minOccurs
maxOccurs
Content
IdentificationPresentUnknownIndicator (Item 18a)
0
1
Simple
OtherIssuerCountryText (Item 18g)
0
1
Simple
OtherIssuerStateText (Item 18f)
0
1
Simple
OtherPartyIdentificationTypeText (Item 18z)
0
1
Simple
PartyIdentificationNumberText (Item 18e)
0
1
Simple
PartyIdentificationTypeCode (Item 18b-d,z)
0
1
Simple
*If unknown is indicated for the subject form of identification, the above subsequent elements should not
be recorded; Unless all information related to the subject form of identification is unknown, the unknown
indicator element should not be recorded.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for the following party types (activity level):
Party type
(min-max)
TCC
(min-max)
TIN
Form of ID
(min-max)
(min-max)
ICN
Transmitter
1-1
1-1
n/a
n/a
Filing Institution
n/a
1-1
0-1
0-1
Financial Institution Where Activity Occurred
n/a
1-1
0-1
0-1
Subject*
n/a
0-1
0-99
n/a
*In the event that all critical subject information is unavailable, do not record the
element for the Subject (33).
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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Element Name:
PartyIdentification
minOccurs:
0
maxOccurs:
100
Example:
US
CA
Student ID
660623559
999
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the Subject TIN and
does not contain a “Y” value.
•
The element is not recorded or does not contain a value for the Subject Form of Identification
and does not contain a “Y” value.
•
More than one identification (other than the Form of ID for the Subject) of the same type is
recorded for a party within a single FinCEN SAR Activity.
Element Name:
IdentificationPresentUnknownIndicator
Description:
Identification unknown (indicator). This element declares that the form of identification used to verify
the identity of the subject is unknown. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
18a. Form of identification for subject (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Record this element when all information related to the Subject (33) form of identification is unknown;
otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Identification unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
OtherIssuerCountryText
Description:
Identification issuing country (code). This element identifies the country where the identification was
issued by (or in) associated with the subject. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
18g. Form of identification for subject – Issuing Country
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Record this element for the Subject (33) party type when the following conditions are true; otherwise,
do not record this element:
•
The identification type is Passport or Alien registration
•
The identification type is Driver’s license/state ID or Other, and the country the identification
was issued in is known
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: Country codes (including U.S. Territory
codes) must adhere to the two-letter country codes found in ISO 3166-2.
The batch submission will be rejected if any of the following conditions are true:
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Element Name:
OtherIssuerCountryText
minOccurs:
0
maxOccurs:
1
maxOccurs:
1
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the Subject when the form of
identification is Passport or Alien registration.
•
The element contains a value and identification unknown is indicated.
•
The element contains a value that is not a valid country code
•
State code and country code mismatch when U.S. Territory is recorded
•
Example:
US
Element Name:
OtherIssuerStateText
Description:
Identification issuing state (code). This element identifies the state where the identification was issued
by (or in) associated with the subject. This element corresponds with the following item(s):
•
minOccurs:
0
18f. Form of identification for subject – Issuing State
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Record this element for the Subject (33) party type when the following conditions are true; otherwise,
do not record this element:
•
The identification type is Driver's license/state ID and the corresponding country is US, CA,
MX, or a U.S. Territory
•
The identification type is Other and the identification was issued by or in a known
state/province/territory of the U.S., a U.S. Territory, Canada, or Mexico.
•
The identification type is Other and the identification was not issues by a national
government.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the Subject when the form of
identification is Driver’s license/State ID.
•
The element contains a value and identification unknown is indicated.
•
The element contains a value that is not a valid state code.
•
State code and country code mismatch when U.S. Territory is recorded.
CA
Element Name:
OtherPartyIdentificationTypeText
Description:
Identification type other description (text). This element identifies the other identification type
associated with the party. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
18z. Form of identification for subject – Other (description)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
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Element Name:
OtherPartyIdentificationTypeText
Element Restriction(s):
Record this element for the Subject (33) party type and "Other" is declared for the form of identification
type; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: 50 characters or less
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value for the Subject when the form of
identification is Other.
•
The element contains a value and identification unknown is indicated.
Student ID
Element Name:
PartyIdentificationNumberText
Description:
Identification number (text). This element identifies the form of identification number associated with
the party. This element corresponds with the following item(s):
minOccurs:
0
maxOccurs:
1
•
Transmitter
o
Transmitter Control Code (TCC) number
o
Taxpayer Identification Number (TIN) number
•
Filing Institution
o
77. TIN (EIN, SSN/ITIN, Foreign) number
o
81. Filing institution identification (CRD, IARD, etc.) number (if known)
o
88. Internal control/file number (if known)
•
Financial Institution Where Activity Occurred
o
59. TIN (EIN, SSN/ITIN, Foreign) number (if known)
o
55. Financial institution identification (CRD, IARD, etc.) number (if known)
o
66. Internal control/file number (if known)
•
Subject
o
o
16. TIN (EIN, SSN/ITIN, Foreign) number (if known)
18. Form of identification (Driver’s license/State ID, Passport, etc.) number (if
known)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Conditionally Required. Record this element for the above party types and conditions, otherwise, do not
record this element. If unknown is indicated for the Financial Institution TIN or the Subject TIN, record
the corresponding unknown element with a “Y” value and do not record this element. For Form of
Identification do not record this element when unknown is indicated but only record the corresponding
unknown element with a "Y" when all Form of Identification data are unknown.
Value Restriction(s):
The value provided must adhere to the following requirements by party type:
•
Transmitter (35)
o
TCC = 8 characters equal to “TBSATEST” (when submitting in the BSA E-Filing User
Test System) or “PBSA8180” (when submitting in the BSA E-Filing Production
System)
o
TIN = 25 characters or less
•
Filing institution (30) and Financial institution where activity occurred (34)
o
EIN/SSN/ITIN = 9 numeric characters
o
Foreign TIN = 25 characters or less
o
Identification number (CRD, IARD, etc.) = 10 characters or less
o
Internal Control Number = 20 characters or less
•
Subject (33)
o
EIN/SSN/ITIN = 9 numeric characters
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Element Name:
PartyIdentificationNumberText
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is not recorded or does not contain a value for the filing institution TIN.
•
The element is not recorded or does not contain a value for the financial institution where
activity occurred TIN and unknown is not indicated.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the EIN or SSN/ITIN is an invalid number string.
•
The element contains a value for the subject form of identification and unknown is indicated.
Example:
minOccurs:
0
maxOccurs:
1
o
Foreign TIN = 25 characters or less
o
Identification (Driver's license, Passport, etc.) = 24 characters or less
All identification numbers must be entered as a single alpha/numeric text string without formatting or
special characters such as, for example, spaces, hyphens, or periods; however, asterisks within the
identification number are accepted for the subject’s form of identification. Cannot be consecutive string
of the same number or an incremental string such as 123456789.
660623559
Element Name:
PartyIdentificationTypeCode
minOccurs:
0
maxOccurs:
Description:
Identification type (code). This element identifies the type of identification associated with the party.
This element corresponds with the following item(s):
•
Transmitter
o
Transmitter Control Code (TCC) type
o
Taxpayer Identification Number (TIN) type
•
Filing Institution
o
78. TIN (EIN, SSN/ITIN, Foreign) type
o
81. Filing institution identification (CRD, IARD, etc.) type
o
88. Internal control/file number type
•
Financial Institution Where Activity Occurred
o
60. TIN (EIN, SSN/ITIN, Foreign) type
o
55. Financial institution identification (CRD, IARD, etc.) type
o
66. Internal control/file number type
•
Subject
o
o
1
17. TIN (EIN, SSN/ITIN, Foreign) type
18. Form of identification (Driver’s license/State ID, Passport, etc.) type
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Required. This element must be recorded for the above party types/conditions; otherwise, do not record
this element.
Value Restriction(s):
The value provided must adhere to the following requirements: Identify the identification type by
recording the appropriate code from the list below (by party type at the activity level):
Code
Description
Party Type (Code)
35
30
34
33
4
Taxpayer Identification Number (TIN)
●
28
Transmitter Control Code (TCC)
●
2
Employer Identification Number (EIN)
●
●
●
1
Social Security Number (SSN)/Individual Taxpayer Identification
Number (ITIN)
●
●
●
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Element Name:
PartyIdentificationTypeCode
Example:
0
maxOccurs:
1
9
Foreign Taxpayer Identification Number (TIN)
●
●
10
Central Registration Depository (CRD) number
●
●
11
Investment Adviser Registration (IARD) number
●
●
12
National Futures Association (NFA ID) number
●
●
14
Research, Statistics, Supervision, and Discount (RSSD) number
●
●
13
Securities and Exchange Commission (SEC) number
●
●
32
National Association of Insurance Commissioners (NAIC) number
●
●
33
National Mortgage Licensing System (NMLS) number
●
●
29
Internal control/file number
●
●
5
Driver's license/State ID
●
6
Passport
●
7
Alien registration
●
Other Identification
●
999
Remarks:
minOccurs:
●
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded and the contains a value.
•
The element contains a value not equal to one of the approved codes listed above.
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value that is not valid for the associated party type.
999
Element Name:
TINUnknownIndicator
Description:
TIN unknown (indicator). This element declares that the TIN associated with the party is unknown. This
element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
Subject: 16a. TIN (unknown)
Financial Institution Where Activity Occurred: 59a. TIN (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Conditionally Required. Record this element for the Financial institution where activity occurred (34) and
Subject (33) part types when the TIN is unknown; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate TIN unknown)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
4.6.5. OrganizationClassificationTypeSubtype Elements
Element Name:
OrganizationClassificationTypeSubtype
Description:
Institution type/subtype (header). This is the container form information about the type and subtype of
institution associated with the party.
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0
maxOccurs:
15
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Element Name:
OrganizationClassificationTypeSubtype
minOccurs:
0
maxOccurs:
15
The following sub-element is associated with this element:
Activity party type code definitions
30 = Filing Institution | 34 = Financial Institution Where Activity Occurred
1.
Filing Institution Information: Type of financial institution (Required | FinCEN SAR Part IV,
Items 79-80)
Name
minOccurs
maxOccurs
Content
OrganizationSubtypeID (Item 80a-n, z)
0
1
Simple
OrganizationTypeID (Item 79a-g, z)
1
1
Simple
OtherOrganizationSubTypeText (Item 80z)
0
1
Simple
OtherOrganizationTypeText (Item 79z)
0
1
Simple
2.
Financial Institution Where Activity Occurred: Type of financial institution (Required | FinCEN
SAR Part III, Items 51, 53-54)
Name
Attribute(s)
minOccurs
maxOccurs
Content
OrganizationSubtypeID (Items 53a-c, z / 54a-k, z)
0
1
Simple
OrganizationTypeID (Item 51a-g, z)
1
1
Simple
OtherOrganizationSubTypeText (Items 53z / 54z)
0
1
Simple
OtherOrganizationTypeText (Item 51z)
0
1
Simple
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for the following party types (activity level):
Party type
Institution
type/subtype
(min-max)
Value Restriction(s):
Remarks:
Filing Institution
1-15
Financial Institution Where Activity Occurred
1-12
*If the Filing institution (30) and/or Financial institution where activity occurred (34) is a Securities and
Futures institution (or individual) and the institution/individual can be classified as more than one type
of Securities and Futures institution, the element may be
recorded multiple times in order to identify all of the associated Securities and Futures subtypes (in
which case each occurrence would identify the same type of institution with the applicable subtype);
however, if the type of institution is not equal to Securities and Futures, then the
should only be recorded once per these party types.
n/a
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
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Element Name:
OrganizationClassificationTypeSubtype
minOccurs:
0
maxOccurs:
Example:
533
5
15
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded for the Financial institution where activity occurred and/or the
Filing institution.
Element Name:
OrganizationSubtypeID
Description:
Institution subtype (code). This element identifies the specific type of gaming or securities/futures
institution. This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
Filing institution
o
80a-n, z. Type of Securities and Futures institution or individual
Financial institution where activity occurred
o
53a-c, z. Type of Gaming institution
o
54a-k, z. Type of Securities and Futures institution or individual
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
OrganizationClassificationTypeSubtype
Element Restriction(s):
Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
•
Filing institution (30) and the type of institution is Securities/Futures (5)
•
Financial institution where activity occurred (34) and the type of institution is either
Casino/Card club (1) or Securities/Futures (5)
Value Restriction(s):
The value provided must adhere to the following requirements:
•
If the party type is associated with the Filing institution (30) or Filing institution where activity
occurred (34) and the type of institution is Securities/Futures (5), then select from the list of
codes to describe the institution subtype:
Code
Description
Party Type (Code)
30
34
●
535
Clearing broker-securities
●
534
CPO/CTA
●
541
Execution-only broker securities
●
●
508
Futures Commission Merchant
●
●
504
Holding Company
●
●
513
Introducing broker-commodity
●
●
540
Introducing broker-securities
●
●
514
Investment adviser
●
●
539
Investment company
●
●
533
Retail foreign exchange dealer
●
●
542
Self-clearing broker-securities
●
●
528
SRO futures
●
529
SRO securities
●
503
Subsidiary of financial/bank holding company
●
●
5999
Other
●
●
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Element Name:
OrganizationSubtypeID
•
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
If the party type is associated with the Financial institution where activity occurred (34) and
the type of institution is Casino/Card club (1), then select from the list of codes to describe
the institution subtype:
Code
Description
101
State casino
102
Tribal casino
103
Card club
1999
Other
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value not equal to one of the approved codes listed above.
•
The element contains a value but the institution type is not equal to Casino/Card club or
Securities and Futures.
•
The value recorded conflicts with the institution type recorded (e.g. State Casino recorded for
Securities and Futures institution)
•
The element is not recorded for the filing institution and the institution type is equal to
Securities and Futures.
•
The element is not recorded for the financial institution where activity occurred and the
institution type is equal to Casino/Card club or Securities and Futures.
•
The element contains a value that has already been recorded for the Activity.
103
Element Name:
OrganizationTypeID
Description:
Institution type (code). This element identifies the type of institution. This element corresponds with the
following item(s):
•
•
minOccurs:
1
maxOccurs:
1
79a-g, z. Type of financial institution: Filing institution
51a-g, z. Type of financial institution: Financial institution where activity occurred
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
OrganizationClassificationTypeSubtype
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
Identify the institution type by recording the appropriate code from the list below:
Code
Remarks:
Description
1
Casino/Card club
2
Depository institution
3
Insurance company
4
MSB (Money Service Business)
5
Securities/Futures
11
Loan or Finance Company
12
Housing GSE (Government Sponsored Enterprise)
999
Other
The batch submission will be rejected if any of the following conditions are true:
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Element Name:
OrganizationTypeID
•
•
minOccurs:
1
maxOccurs:
1
0
maxOccurs:
1
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
Example:
1
Element Name:
OtherOrganizationSubTypeText
Description:
Institution subtype other (description). This element identifies the other type of gaming or
securities/futures institution. This element corresponds with the following item(s):
•
•
minOccurs:
Filing institution
o
80z. Type of Securities and Futures institution or individual (other description)
Financial institution where activity occurred
o
53z. Type of Gaming institution (other description)
o
54z. Type of Securities and Futures institution or individual (other description)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
OrganizationClassificationTypeSubtype
Element Restriction(s):
Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
•
Filing institution (30), the type of institution is Securities/Futures (5), and the
element contains the value "5999" (Other)
•
Financial institution where activity occurred (34) and:
o
The type of institution is Casino/Card club (1) and the
element contains the value "1999" (Other)
o
The type of institution is Securities/Futures (5) and the
element contains the value "5999" (Other)
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 50 characters or less.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value and the institution subtype is equal
to Other.
•
The element is recorded with a value but the institution subtype is not equal to Other.
other description
Element Name:
OtherOrganizationTypeText
Description:
Institution type other (description). This element identifies the description of the other gaming or
securities/futures institution. This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
79z. Type of financial institution: Filing institution (other description)
51z. Type of financial institution: Financial institution where activity occurred (other
description)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
OrganizationClassificationTypeSubtype
Element Restriction(s):
Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
•
Filing institution (30) and the element contains the value "999" (Other)
•
Financial institution where activity occurred (34) and the element
contains the value "999" (Other)
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: 50 characters or less.
The batch submission will be accepted with warning if any of the following conditions are true:
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Element Name:
OtherOrganizationTypeText
•
•
Example:
minOccurs:
0
maxOccurs:
1
The element is not recorded or does not contain a value and the institution type is equal to
Other.
The element is recorded with a value but the institution type is not equal to Other.
other description
4.6.6. PartyOccupationBusiness Elements
Element Name:
PartyOccupationBusiness
minOccurs:
0
maxOccurs:
1
Description:
Occupation or type of business (header). This is the container for information about the occupation or
type of business of the subject.
The following sub-element is associated with this element:
Activity party type code definitions
33 = Subject
1.
Subject: Occupation or type of business (if available | FinCEN SAR Part I, Item 10/10a)
Name
minOccurs
maxOccurs
Content
NAICSCode (Item 10a)
0
1
Simple
OccupationBusinessText (Item 10
0
1
Simple
*If the element is recorded for the Subject (33), then at least one of the above
elements should be recorded with a valid value.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Record this element when the occupation/type of business and/or NAICS Code is known for the Subject
(33) party type; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
n/a
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
7548
Mechanic
Element Name:
NAICSCode
Description:
NAICS Code (text). This element identifies the North American Industry Classification System (NAICS)
code for the occupation or type of business of the subject. This element corresponds with the following
item(s):
•
minOccurs:
0
maxOccurs:
1
10a. NAICS Code: Subject
Please refer to Attachment C for additional information regarding the above item(s).
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Element Name:
Attribute(s)
NAICSCode
minOccurs:
0
maxOccurs:
1
n/a
Parent Element:
PartyOccupationBusiness
Element Restriction(s):
Record this element when known and the party type is associated with the Subject (33); otherwise, do
not record this element.
Remarks:
The value provided must adhere to the following requirements: 3-6 digit numeric characters. Use the list
of NAICS Codes authorized for use in the FinCEN SAR located on the BSA E-Filing Web Site
(http://bsaefiling.fincen.treas.gov) or from the U.S. Census Bureau NAICS list. Select a code that mostclosely relates to the occupation or type of business recorded for the subject in the
element.
n/a
Example:
7548
Element Name:
OccupationBusinessText
Description:
Occupation or type of business (description). This element identifies the description of the occupation,
profession, or type of business of the subject. This element corresponds with the following item(s):
Value Restriction(s):
•
minOccurs:
0
maxOccurs:
1
10. Occupation or type of business: Subject
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyOccupationBusiness
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject's
occupation, profession, or type of business is known; otherwise, do not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: 30 characters or less
Remarks:
n/a
Example:
Mechanic
4.6.7. ElectronicAddress Elements
Element Name:
ElectronicAddress
Description:
Electronic address (header). This is the container for information about the subject's e-mail address or
website URL (Uniform Resource Locator).
minOccurs:
0
maxOccurs:
198
The following sub-element is associated with this element:
Activity party type code definitions
33 = Subject
1.
Subject:
a.
E-mail address (if available | FinCEN SAR Part I, Item 22)
Name
minOccurs
maxOccurs
Content
ElectronicAddressText (Item 22)
1
1
Simple
ElectronicAddressTypeCode (Code E)
1
1
Simple
*If the element is recorded for the Subject’s (33) e-mail address, then the above
elements should be recorded with a valid value for each.
b.
Website (URL) address (if available | FinCEN SAR Part I, Item 22a)
Name
ElectronicAddressText (Item 22a)
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minOccurs
maxOccurs
Content
1
1
Simple
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Element Name:
ElectronicAddress
minOccurs:
0
ElectronicAddressTypeCode (Code U)
maxOccurs:
1
198
1
Simple
*If the element is recorded for the Subject’s (33) website URL address, then the above
elements should be recorded with a valid value for each.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Record this element for the Subject (33) party type when the e-mail address and/or website URL
address is known; otherwise, do not record this element.
The following table describes the minimum and maximum reporting requirements for this element:
Party type
E-mail
URL
(min-max)
(min-max)
0-99
0-99
Subject
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
[email protected]
E
https://www.will_mann.org/
U
Element Name:
ElectronicAddressText
Description:
Electronic address (text). This element identifies the subject's email address or website URL (Uniform
Resource Locator) address. This element corresponds with the following item(s):
•
Subject
o
o
minOccurs:
1
maxOccurs:
1
22. E-mail address (if available)
22a. Website (URL) address (if available)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ElectronicAddress
Element Restriction(s):
Record this element when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
E-mail address: 50 characters or less; the value must contain the "@" sign followed by at least
one period (e.g. [email protected])
•
Website (URL) address: 517 characters or less; the values should contain at least one period.
Remarks:
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not a valid email address or URL format.
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ElectronicAddressText
minOccurs:
Element Name:
ElectronicAddressTypeCode
minOccurs:
Description:
Electronic address type (code). This element identifies the type of electronic address recorded for the
subject; specifically whether it is an email address or a website URL (Uniform Resource Locator) address.
This element corresponds with the following item(s):
Element Name:
Example:
1
maxOccurs:
1
[email protected]
E
https://www.will_mann.org/
U
•
Subject
o
o
1
maxOccurs:
1
22. E-mail address type
22a. Website (URL) type
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ElectronicAddress
Element Restriction(s):
Record this element when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
Identify the electronic address type by recording the appropriate code from the list below:
Code
Remarks:
Example:
Description
E
E-mail address
U
Website (URL) address
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value (i.e. the value is null).
•
The value recorded is an invalid code.
[email protected]
E
https://www.will_mann.org/
U
4.6.8. PartyAssociation Elements
Element Name:
PartyAssociation
Description:
Party association (header). This is the container for information about the subject's relationship to the
institution recorded in the FinCEN SAR, as well as information about the branch where activity occurred.
minOccurs:
0
maxOccurs:
99
The following tables describe all possible sub-elements for each activity level party type:
Activity party type code definitions
33 = Subject | 34 = Financial institution where activity occurred
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Element Name:
PartyAssociation
1.
minOccurs:
0
maxOccurs:
99
Subject: Relationship of subject to an institution recorded in Part III or IV (FinCEN SAR Part I,
Items 24-26)
Name
minOccurs
maxOccurs
Content
AccountantIndicator (Item 24b)
0
1
Simple
ActionTakenDateText (Item 26)
0
1
Simple
AgentIndicator (Item 24c)
0
1
Simple
AppraiserIndicator (Item 24d)
0
1
Simple
AttorneyIndicator (Item 24e)
0
1
Simple
BorrowerIndicator (Item 24f)
0
1
Simple
CustomerIndicator (Item 24g)
0
1
Simple
DirectorIndicator (Item 24h)
0
1
Simple
EmployeeIndicator (Item 24i)
0
1
Simple
NoRelationshipToInstitutionIndicator (Item 24j)
0
1
Simple
OfficerIndicator (Item 24k)
0
1
Simple
OtherPartyAssociationTypeText (Item 24z)
0
1
Simple
OtherRelationshipIndicator (Item 24z)
0
1
Simple
OwnerShareholderIndicator (Item 24l)
0
1
Simple
RelationshipContinuesIndicator (Item 25a)
0
1
Simple
ResignedIndicator (Item 25d)
0
1
Simple
SubjectRelationshipFinancialInstitutionTINText (Item 24a)
0
1
Simple
SuspendedBarredIndicator (Item 24c)
0
1
Simple
TerminatedIndicator (Item 25b)
0
1
Simple
*If the element is recorded for the Subject (33), then at least one of the above
relationship indicator elements should be recorded with a valid value.
2.
Financial institution where activity occurred: Branch location (FinCEN SAR Part III, Items 68, 69,
70-74)
Name
Party (Items 68, 69, 70-74)
Attribute(s)
minOccurs
maxOccurs
Content
0
99
Complex
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Record this element under the following circumstances; otherwise do not record this element:”
•
The party recorded is associated with the Subject (33) and the relationship of the subject to
the filing institution and/or the financial institution(s) where activity occurred is being
recorded..
NOTE: If the subject does not have a relationship with any of the recorded institutions in Part
III or IV, record a single element for the subject where the element
is recorded with a "Y" value and the TIN of the filing
institution is recorded for the element. The
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Element Name:
PartyAssociation
minOccurs:
0
maxOccurs:
99
element should not be recorded for the subject if a
relationship exists with any institution recorded in Part III or IV, even when there is no
relationship with other institutions.
•
The party recorded is associated with the financial institution where activity occurred (34) and
activity occurred at a branch location.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded but at least one indicator identifying the type of relationship is not
recorded with a "Y" value. .
Example:
Relationship of subject to an institution:
Y
20170905
Y
458789856
Branch where activity occurred:
46
Y
Cityville
US
VA
123 Road
547898856
154879885
14
Element Name:
AccountantIndicator
Description:
Accountant (indicator). This element declares that the subject’s relationship to the institution can be
described as "Accountant." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24b. Relationship of subject to institution: Accountant
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
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Element Name:
AccountantIndicator
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: "Y" (to indicate Accountant)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
ActionTakenDateText
Description:
Action date (date). This element identifies the date on which the action was taken in the event that the
relationship no longer continues between the subject and the institution. This element corresponds with
the following item(s):
•
minOccurs:
0
maxOccurs:
1
26. Relationship of subject to institution: Action date
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the status of the subject
relationship to the institution TIN recorded for the
element has be identified as Terminated, Suspended/barred, or Resigned; otherwise, do not record this
element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value and the status of the relationship is
Terminated, Suspended/barred, or Resigned.
•
The element is recorded with a valid value but the status of the relationship is not equal to
Terminated, Suspended/barred, or Resigned.
•
The value recorded for the element is not in the required format (YYYYMMDD).
20170905
Element Name:
AgentIndicator
Description:
Agent (indicator). This element declares that the subject’s relationship to the institution can be
described as "Agent." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24c. Relationship of subject to institution: Agent
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: "Y" (to indicate Agent)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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Element Name:
AgentIndicator
Example:
Y
Element Name:
AppraiserIndicator
Description:
Appraiser (indicator). This element declares that the subject’s relationship to the institution can be
described as "Appraiser." This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
0
maxOccurs:
1
The value recorded is not equal to “Y” or not equal to null.
minOccurs:
24d. Relationship of subject to institution: Appraiser
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Appraiser)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
AttorneyIndicator
Description:
Attorney (indicator). This element declares that the subject’s relationship to the institution can be
described as "Attorney." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24e. Relationship of subject to institution: Attorney
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Attorney)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
BorrowerIndicator
Description:
Borrower (indicator). This element declares that the subject’s relationship to the institution can be
described as "Borrower." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24f. Relationship of subject to institution: Borrower
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
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Element Name:
BorrowerIndicator
minOccurs:
0
maxOccurs:
1
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate Borrower)
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Example:
Y
Element Name:
CustomerIndicator
Description:
Customer (indicator). This element declares that the subject’s relationship to the institution can be
described as "Customer." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24g. Relationship of subject to institution: Customer
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Customer)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
DirectorIndicator
Description:
Director (indicator). This element declares that the subject’s relationship to the institution can be
described as "Director." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24h. Relationship of subject to institution: Director
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Director)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a “Y” value for the subject and contains
a “Y” value.
Y
Element Name:
EmployeeIndicator
Description:
Employee (indicator). This element declares that the subject’s relationship to the institution can be
described as "Employee." This element corresponds with the following item(s):
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0
maxOccurs:
1
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Element Name:
EmployeeIndicator
•
minOccurs:
0
maxOccurs:
1
24i. Relationship of subject to institution: Employee
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate Employee)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a “Y” value for the subject and contains
a “Y” value.
Y
Element Name:
NoRelationshipToInstitutionIndicator
Description:
No relationship to institution (indicator). This element declares that the subject has no relationship with
any of the financial institutions recorded in the FinCEN SAR. This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
24j. Relationship of subject to institution: No relationship to institution
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the subject does not
have a relationship with filing institution or financial institution(s) where activity occurred*; otherwise, do
not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate "No relationship to an
institution")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Value Restriction(s):
Remarks:
Example:
Y
Element Name:
OfficerIndicator
Description:
Officer (indicator). This element declares that the subject’s relationship to the institution can be
described as "Officer." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24k Relationship of subject to institution: Officer
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: "Y" (to indicate Officer)
The batch submission will be rejected if any of the following conditions are true:
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Element Name:
OfficerIndicator
minOccurs:
0
maxOccurs:
1
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a “Y” value for the subject and contains
a “Y” value.
•
Example:
Y
Element Name:
OtherPartyAssociationTypeText
Description:
Other relationship (description). This element declares that the subject's relationship to the institution is
not covered by any of pre-defined options. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24z. Relationship of subject to institution: Other (description)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when the party type is associated with the Subject (33) and the
element contains a "Y" value; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 50 characters or less.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value and Other is indicated.
•
The element is recorded with a value and Other is not indicated.
Other description
Element Name:
OtherRelationshipIndicator
Description:
Other relationship (indicator). This element describes the other type of relationship between the subject
and the institution. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24z. Relationship of subject to institution: Other (indicator)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element cannot be categorized by one of the
pre-defined indicator elements; otherwise, do not record this element. If this element is recorded with a
"Y" value, please ensure a brief description of the relationship type is recorded in the
element.
The value provided must adhere to the following requirements: "Y" (to indicate "Other relationship")
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
Y
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Element Name:
OwnerShareholderIndicator
Description:
Owner or controlling shareholder (indicator). This element declares that the subject’s relationship to the
institution can be described as "Owner or controlling shareholder." This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
24l. Relationship of subject to institution: Owner or Controlling Shareholder
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the element; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Owner or controlling
shareholder")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a “Y” value for the subject and contains
a “Y” value.
Y
Element Name:
RelationshipContinuesIndicator
Description:
Relationship continues (indicator). This element declares that the status of the subject’s relationship to
the institution can be described as "Relationship continues." This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
25a. Relationship status of subject to institution: Relationship continues
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate "Relationship
continues")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
•
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Value Restriction(s):
Remarks:
Example:
Y
Element Name:
ResignedIndicator
Description:
Resigned (indicator). This element declares that the status of the subject’s relationship to the institution
can be described as "Resigned." This element corresponds with the following item(s):
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0
maxOccurs:
1
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Element Name:
ResignedIndicator
•
minOccurs:
0
maxOccurs:
1
25d. Relationship status of subject to institution: Resigned
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
The value provided must adhere to the following requirements: "Y" (to indicate Resigned)
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
•
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Y
Element Name:
SubjectRelationshipFinancialInstitutionTINText
Description:
Institution TIN (text). This element identifies the TIN of the institution recorded in the FinCEN SAR that
the subject has a relationship with. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
24a. Relationship of subject to institution: Institution TIN
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element for the Subject (33) party type in order to identify the TIN (if known) associated
with the filing institution or financial institution where activity occurred in which the subject has a
relationship with; otherwise, do not record this element. If the subject has no relationship with any of
these institutions, record the TIN of the filing institution for this element and record a "Y" value for the
element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 25 characters or less. The number
recorded must match the TIN recorded for the filing institution or the financial institution where activity
occurred.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded does not match the TIN for the Filing institution or the Financial
institution where the activity occurred.
458789856
Element Name:
SuspendedBarredIndicator
Description:
Suspended/Barred (indicator). This element declares that the status of the subject’s relationship to the
institution can be described as "Suspended/Barred." This element corresponds with the following
item(s):
•
minOccurs:
0
maxOccurs:
1
25c. Relationship status of subject to institution: Suspended/barred
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Element Name:
SuspendedBarredIndicator
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
Value Restriction(s):
minOccurs:
0
maxOccurs:
Please refer to Attachment C for additional information regarding the above item(s).
1
The value provided must adhere to the following requirements: "Y" (to indicate Suspended/Barred)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
•
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Remarks:
Example:
Y
Element Name:
TerminatedIndicator
Description:
Terminated (indicator). This element declares that the status of the subject’s relationship to the
institution can be described as "Terminated." This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
25d. Relationship status of subject to institution: Terminated
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: "Y" (to indicate Terminated)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
•
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Remarks:
Example:
Y
Element Name:
4.6.8.1.
Party
See Party Elements (below) for details.
Party Elements
The following Party element (and associated sub-elements) corresponds with the Part III Branch location where
activity occurred. In the event that the FinCEN SAR involves branch locations, up to 99 branch locations may be
reported; otherwise, this Party element should not be recorded.
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Element Name:
Party
minOccurs:
0
maxOccurs:
99
Description:
Party (header). This is the container for information about the individual or entity associated with the
FinCEN SAR; specifically, the branch location where activity occurred.
The following tables describe all possible sub-elements for the Branch (46) party type:
Activity party type code definitions
46 = Branch location were activity occurred
1.
Financial institution where activity occurred: Branch location (FinCEN SAR Part III, Items 68, 69,
70-74)
Name
Attribute(s)
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 46)
1
1
Simple
PayLocationIndicator (Item 68b)
0
1
Simple
SellingLocationIndicator (Item 68a)
0
1
Simple
SellingPayingLocationIndicator (Item 68c)
0
1
Simple
Address (Items 69, 71-74)
1
1
Complex
PartyIdentification (Item 70)
0
1
Complex
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
PartyAssociation
Element Restriction(s):
Record this element if the associated financial institution has a branch involved in the suspicious
activity; otherwise, do not record this element. 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. Generally,
a branch operates under the same TIN as the financial institution. Up to 99 branches may be recorded
for a single FinCEN SAR.
Value Restriction(s):
Remarks:
Example:
n/a
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
•
More than 99 branches are recorded for the FinCEN SAR.
See Part Elements by Party Type for a detailed example…
Element Name:
ActivityPartyTypeCode
Description:
Party type (code). This element identifies the type of party associated with the FinCEN SAR; specifically,
the branch where activity occurred.
Attribute(s)
minOccurs:
1
maxOccurs:
1
n/a
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for each element regardless of party type.
Value Restriction(s):
The value provided must adhere to the following requirements:
Code
46
Description
Branch where activity occurred
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Element Name:
Remarks:
Example:
ActivityPartyTypeCode
minOccurs:
1
maxOccurs:
1
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but with no value (i.e. the value is null).
•
The element contains a value not equal to “46”.
46
Element Name:
PayLocationIndicator
Description:
Paying location (indicator). This element declares that the customer received payment from the branch
for the products or instruments recorded in the FinCEN SAR. This element corresponds with the
following item(s):
•
minOccurs:
0
68b. Branch’s role in transaction (Paying location)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Branch Where Activity Occurred (46) and
the customer received payment from the branch (46) for the recorded products or instruments;
otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Paying location")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one role is recorded for the branch’s role in the transaction.
Y
Element Name:
SellingLocationIndicator
Description:
Selling location (indicator). This element declares that the branch sold the products or instruments
recorded in the FinCEN SAR. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
68a. Branch’s role in transaction (Selling location)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Branch Where Activity Occurred (46)
and the branch sold the recorded products or instruments; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Selling location")
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one role is recorded for the branch’s role in the transaction.
Y
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Element Name:
SellingPayingLocationIndicator
Description:
Selling and Paying location (indicator). This element declares that the branch was both a paying and
selling location for the products or instruments recorded in the FinCEN SAR. This element corresponds
with the following item(s):
•
minOccurs:
0
maxOccurs:
1
68c. Branch’s role in transaction (both Selling and Paying location)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the party type is associated with the Branch Where Activity Occurred (46) and
the branch was both the selling and paying location for the recorded products or instruments;
otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate both Selling and Paying
location)
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
More than one role is recorded for the branch’s role in the transaction.
Y
Element Name:
Address
See Address Elements (below) for details.
Element Name:
PartyIdentification
See PartyIdentification Elements (below) for details.
4.6.8.1.1.
Address Elements
Element Name:
Address
Description:
Address (header). This is the container for information about the address of the party; specifically, the
branch where activity occurred. The following tables describe all possible sub-elements for the Branch
(46) party type:
1.
minOccurs:
1
maxOccurs:
99
Branch: Address (FinCEN SAR Part III, Items 69, 71-74)
Name
minOccurs
maxOccurs
Content
RawCityText
0
1
Simple
RawCountryCodeText
1
1
Simple
RawStateCodeText
0
1
Simple
RawStreetAddress1Text
0
1
Simple
RawZIPCode
0
1
Simple
*If the element is recorded for the Branch (46) party type, then the
must contain a value in addition to any other known address elements.
Attribute(s)
Parent Element:
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Party
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Element Name:
Address
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded for the branch location.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The element is not recorded for the branch location.
Example:
minOccurs:
1
maxOccurs:
99
Cityville
US
VA
123 Address Way
547898856
Element Name:
RawCityText
Description:
City (text). This element identifies the city associated with the address of the branch. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
Branch: 71. City
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Record this element for the Branch (46) where activity occurred party type when the city associated
with the branch address is known; otherwise, do not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: 50 characters or less
Remarks:
•
None
Example:
Rockville
Element Name:
RawCountryCodeText
Description:
Country (code). This element identifies the country associated with the branch. This element
corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
Branch: 74. Country
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: Country codes (including U.S. Territory
codes) must adhere to the two-letter country codes found in ISO 3166-2.
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not a valid country code.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
State code and country code mismatch when U.S. Territory is recorded.
Remarks:
Example:
US
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Element Name:
RawStateCodeText
Description:
State/Territory/Province (code). This element identifies the state/territory/province associated with the
address of the branch when the corresponding country is equal to US (United States), CA (Canada), MX
(Mexico), or a U.S. Territory. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
Branch: 72. State
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Record this element for the Branch (46) where activity occurred party type and the corresponding
country is US (United States), CA (Canada), MX (Mexico), or a U.S. Territory*; otherwise, do not record
this element.
*If the country is a U.S. Territory, record the same U.S. Territory code for the state.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not a valid country code.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element contains a value and the country is not US, CA, MX, or a U.S. Territory.
•
The element is not recorded or does not contain a value when the country is US, CA, MX, or a
U.S. Territory.
•
State code and country code mismatch when U.S. Territory is recorded.
VA
Element Name:
RawStreetAddress1Text
Description:
Street address (text). This element identifies the street address of the branch. This element corresponds
with the following item(s):
•
minOccurs:
0
maxOccurs:
1
Branch: 69. Street Address
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
Element Restriction(s):
Record this element for the Branch (46) where activity occurred party type when the street address
associated with the branch address is known; otherwise, do not record this element.
Value Restriction(s):
The value provided must adhere to the following requirements: 100 characters or less
Remarks:
•
None
Example:
123 Address Way
Element Name:
RawZIPCode
Description:
ZIP/Postal Code (text). This element identifies the ZIP Code or foreign postal code associated with the
address of the branch. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
Branch: 73. ZIP/Postal Code
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Address
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Element Name:
RawZIPCode
Element Restriction(s):
Record this element for the Branch (46) where activity occurred party type when the ZIP/Postal Code
associated with the branch address is known; otherwise, do not record this element.
Value Restriction(s):
Remarks:
0
maxOccurs:
1
The value provided must adhere to the following requirements: For a U.S. address (including U.S.
Territories): 5 or 9 numeric character entry; 9 numeric character entry cannot end with four zeros or four
nines. For a non-U.S. address: 9 (or less) character entry. Do not include punctuation or formatting such
as hyphens, periods, and spaces within the value entry
•
Example:
minOccurs:
None
547898856
4.6.8.1.2.
PartyIdentification Elements
Element Name:
PartyIdentification
minOccurs:
0
maxOccurs:
1
Description:
Party identification (header). This is the container for information about the identification associated
with the branch, specifically, the Research, Statistics, Supervision, and Discount (RSSD) number.
The following tables describe all possible sub-elements for the Branch (46) party type:
2.
Branch: RSSD number (FinCEN SAR Part III, Item 70)
Name
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 70)
1
1
Simple
PartyIdentificationTypeCode (Item 70)
1
1
Simple
*If the element is recorded for the Branch (46) party type, then the above elements
must contain a valid value for each.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Record this element if the RSSD number is known for the Branch (46) party type; otherwise, do not
record this element.
Value Restriction(s):
Remarks:
Example:
n/a
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
445564615654
14
Element Name:
PartyIdentificationNumberText
Description:
Identification number (text). This element identifies the RSSD number associated with the branch. This
element corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
Branch: 70. RSSD number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
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Element Name:
PartyIdentificationNumberText
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 20 numeric characters or less
Remarks:
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
Example:
minOccurs:
1
maxOccurs:
1
445564615654
Element Name:
PartyIdentificationTypeCode
Description:
Identification type (code). This element identifies the type of identification number associated with the
branch as an "RSSD" number. This element corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
Branch: 70. RSSD number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: “14” (to identify the number recorded
as the RSSD number)
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value
•
The value recorded is not equal to “14”.
Remarks:
Example:
14
ALERT: This is the end of the elements associated with the Part III Branch location where activity occurred.
The following PartyAccountAssociation element corresponds with the Subject party type only.
4.6.9. PartyAccountAssociation Elements
The following PartyAccountAssociation element (and associated sub-elements) corresponds with the Part I Item 27
Financial institution TIN and account number(s) affected that are related to the subject. This element should not be
recorded for the subject in the event that there are no known accounts involved related to the subject (in which case
the NoKnownAccountInvolvedIndicator element would be recorded with a “Y” value for the subject). Please refer to
the Item 27 Item Instructions (Attachment C) for additional information.
Element Name:
PartyAccountAssociation
minOccurs:
0
maxOccurs:
1
Description:
Party account association (header). This is the container element for information about the financial
institution and account(s) related to the subject.
The following sub-element is associated with this element:
Activity party type code definitions
33 = Subject
1.
Subject: Financial institution TIN and account number(s) affected that are related to the
subject (if any) (FinCEN SAR Part I, Item 27b-e)
Name
minOccurs
maxOccurs
Content
PartyAccountAssociationTypeCode (Code 7)
1
1
Simple
Party (Items 27b-e)
1
99
Complex
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Element Name:
PartyAccountAssociation
minOccurs:
0
maxOccurs:
1
*If the element is recorded for the Subject (33), then the above elements must
be recorded.
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Conditionally Required. Record this element for the Subject (33) party type when information about
account(s) involved in the suspicious activity (related to the subject) exist; otherwise do not record this
element and record the element with a "Y" value. 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.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is recorded but the element is also
recorded with a “Y” value.
•
The element is not recorded and the element is not
recorded with a “Y” value.
Example:
7
Element Name:
PartyAccountAssociationTypeCode
Description:
Party account association type (code). This element is for FinCEN purposes only.
Attribute(s)
n/a
Parent Element:
PartyAccountAssociation
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: "7" (to link the subject to the account)
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded is not equal to “7”.
Example:
minOccurs:
1
maxOccurs:
1
7
Element Name:
4.6.9.1.
Party
See Party Elements (below) for details.
Party Elements
The following Party element (and associated sub-elements) corresponds with the Part I Item 27 Financial institution
TIN and account number(s) affected that are related to the subject. Unless there are no known accounts involved
related to a subject (in which case the NoKnownAccountInvolvedIndicator element is recorded with a “Y” value for the
subject and, as a result, the PartyAccountAssociation element is not recorded), up to 99 financial institutions’ where
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account(s) are held may be reported for each subject. Please refer to the Item 27 Item Instructions (Attachment C) for
additional information.
Element Name:
Party
Description:
Party (header). This is the container for information about the financial institution in which the account
related to the subject is held.
minOccurs:
1
maxOccurs:
99
The following sub-element is associated with this element:
Activity party type code definitions
41 = Financial institution where account is held
1.
Subject: Financial institution TIN (FinCEN SAR Part I, Item 27b-c)
Name
Attribute(s)
minOccurs
maxOccurs
Content
ActivityPartyTypeCode (Code 41)
1
1
Simple
NonUSFinancialInstitutionIndicator (Item 27b)
0
1
Simple
PartyIdentification (Item 27c)
0
1
Complex
Account (Item 27 d-e)
0
99
Complex
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
PartyAccountAssociation
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
•
More than 99 Financial Institutions Where Account is Held are recorded for the FinCEN SAR.
Example:
See Part Elements by Party Type for a detailed example…
Element Name:
ActivityPartyTypeCode
Description:
Party type (code). This element identifies the type of party associated with the FinCEN SAR; specifically
the financial institution where the account is held.
Attribute(s)
minOccurs:
1
maxOccurs:
1
n/a
Parent Element:
Party
Element Restriction(s):
Required. This element must be recorded for each element regardless of party type.
Value Restriction(s):
The value provided must adhere to the following requirements:
Code
41
Remarks:
Description
Financial institution where account is held
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but with no value (i.e. the value is null).
•
The element contains a value not equal to “41”.
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Element Name:
ActivityPartyTypeCode
Example:
41
Element Name:
NonUSFinancialInstitutionIndicator
Description:
Non-U.S. financial institution (indicator). This element declares that the account is located at a foreign
financial institution. This element corresponds with the following item(s):
•
minOccurs:
minOccurs:
1
0
maxOccurs:
1
maxOccurs:
1
27b. Non-U.S. financial institution
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Party
Element Restriction(s):
Record this element when the Financial institution where the account is held (41) party type and the
location of the institution is not within the U.S. or a U.S. Territory; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Non U.S. financial
institution)
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
PartyIdentification
See PartyIdentification Elements (below) for details.
Element Name:
Account
See Account Elements (below) for details.
4.6.9.1.1.
PartyIdentification Elements
Element Name:
PartyIdentification
minOccurs:
0
maxOccurs:
1
Description:
Party identification (header). This is the container for information about the TIN associated with the
financial institution in which the account is held.
The following sub-element is associated with this element:
Activity party type code definitions
41 = Financial institution where account is held
1.
Subject: Financial institution TIN (FinCEN SAR Part I, Item 27c)
Name
Attribute(s)
Parent Element:
minOccurs
maxOccurs
Content
PartyIdentificationNumberText (Item 27c)
1
1
Simple
PartyIdentificationTypeCode (Code 4)
1
1
Simple
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Party
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Element Name:
PartyIdentification
Element Restriction(s):
Record this element when the TIN of the financial institution where the account is held is known;
otherwise, do not record this element.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
minOccurs:
0
maxOccurs:
1
458789856
4
Element Name:
PartyIdentificationNumberText
Description:
Identification number (text). This element identifies the Taxpayer Identification Number (TIN) associated
with the financial institution in which the account is held. This element corresponds with the following
item(s):
•
minOccurs:
1
maxOccurs:
1
27c. Financial Institution TIN related to subject
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Required. Record this element if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 25 characters or less. Identification
numbers must be entered as a single alpha/numeric text string without formatting or special characters
such as, for example, spaces, hyphens, or periods. Cannot be consecutive string of the same number or
an incremental string such as 123456789.
Remarks:
Example:
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
458789856
Element Name:
PartyIdentificationTypeCode
Description:
Identification type (code). This element identifies the type of identification number associated with
financial institution in which the account is held as a "TIN." This element corresponds with the following
item(s):
•
minOccurs:
1
maxOccurs:
1
27c. Financial Institution TIN type related to subject
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyIdentification
Element Restriction(s):
Required. Record this element if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: “4” (to indicate TIN)
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded does not equal “4”.
Example:
4
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4.6.9.1.2.
Account Elements
Element Name:
Account
minOccurs:
0
maxOccurs:
99
Description:
Account (header). This is the container for information about the account (held at the corresponding
financial institution) involved in the suspicious activity related to the recorded subject.
The following sub-element is associated with this element:
Activity party type code definitions
41 = Financial institution where account is held
1.
Subject: Financial institution TIN (FinCEN SAR Part I, Item 27 d-e)
Name
Attribute(s)
minOccurs
maxOccurs
Content
AccountNumberText (Item 27d)
1
1
Simple
PartyAccountAssociation (Item 27e)
1
1
Complex
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Party
Element Restriction(s):
Record this element for the Financial institution where the account is held (41) party type when the
account number involved in the suspicious activity (related to the subject*) is known**; otherwise do not
record this element.
*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.
**If the filer is aware that the subject has an account involved in the suspicious activity with the
recorded financial institution but the account number is unknown, record the
element with the TIN of the financial institution (41) party type and
do not record the element. Provide an explanation for the missing account number in the
narrative.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
1502417873
Element Name:
AccountNumberText
Description:
Account number (text). This element identifies the account number involved in the suspicious activity
related to the recorded subject. This element corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
27d. Account number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Account
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
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Element Name:
AccountNumberText
minOccurs:
1
maxOccurs:
1
Value Restriction(s):
The value provided must adhere to the following requirements: 40 characters or less
Remarks:
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
Example:
1502417873
Element Name:
PartyAccountAssociation
4.6.9.1.3.
See PartyAccountAssociation Elements (below) for details.
PartyAccountAssociation Elements
Element Name:
PartyAccountAssociation
minOccurs:
1
maxOccurs:
1
Description:
Party account association (header). This is the container for creating the association of the account to
the Financial institution where the account is held, as well as indicating whether or not the account is
closed.
The following sub-element is associated with this element:
Activity party type code definitions
41 = Financial institution where account is held
1.
Subject: Financial institution TIN and account number(s) affected that are related to the
subject (if any) (FinCEN SAR Part I, Item 27e)
Name
Attribute(s)
minOccurs
maxOccurs
Content
AccountClosedIndicator
0
1
Simple
PartyAccountAssociationTypeCode (Code 5)
1
1
Simple
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Account
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
Y
5
Element Name:
AccountClosedIndicator
Description:
Account closed (indicator). This element declares that the recorded account is closed. This element
corresponds with the following item(s):
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0
maxOccurs:
1
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Element Name:
AccountClosedIndicator
•
minOccurs:
0
maxOccurs:
1
27e. Account closed
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
PartyAccountAssociation
Element Restriction(s):
Record this element for the Financial institution where the account is held (41) party type when the
associated account is closed; otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Account closed")
The batch submission will be rejected if any of the following conditions are true:
•
The element contains a value not equal to “Y” or null.
Y
Element Name:
PartyAccountAssociationTypeCode
Description:
Party account association type (code). This element is for FinCEN purposes only.
Attribute(s)
n/a
Parent Element:
PartyAccountAssociation
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: "5" (to link the Financial institution to
the account)
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded is not equal to “5”.
Remarks:
Example:
minOccurs:
1
maxOccurs:
1
5
ALERT: This is the end of the elements associated with the Part I Item 27 Financial institution TIN and account
number(s) affected that are related to the subject. The following SuspiciousActivity element corresponds with the
FinCEN SAR activity.
4.7. SuspiciousActivity Elements
Element Name:
SuspiciousActivity
Description:
minOccurs:
1
maxOccurs:
1
Suspicious Activity (header). This element is the container for information about the suspicious activity,
such as the total amount involved and the type of suspicious activity.
The following sub-element is associated with this element:
Name
minOccurs
maxOccurs
AmountUnknownIndicator (Item 29a)
0
1
Simple
NoAmountInvolvedIndicator (Item 29b)
0
1
Simple
CumulativeTotalViolationAmountText (Item 31)
SuspiciousActivityFromDateText (Item 30a)
SuspiciousActivityToDateText (Item 30b)
TotalSuspiciousAmountText (Item 29)
SuspiciousActivityClassification (Items 32-42)
0
1
0
0
1
1
1
1
1
99
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
Category
Simple
Simple
Simple
Simple
Complex
The following attributes must be recorded for this element:
Name
Description
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Element Name:
SuspiciousActivity
SeqNum
minOccurs:
1
maxOccurs:
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
1
20171001
20171030
20000
other type of suspicious activity
description
915
9
Element Name:
AmountUnknownIndicator
Description:
Amount unknown (indicator). This element declares that the total dollar amount involved in the FinCEN
SAR for the time period being reported is unknown. This element corresponds with the following
item(s):
•
minOccurs:
0
maxOccurs:
1
29a. Amount involved in this report (unknown)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivity
Element Restriction(s):
Record this element when the dollar amount involved in the FinCEN SAR being filed is unknown;
otherwise, do not record this element. If unknown, provide an explanation as to why the dollar amount
is unknown in narrative. If some dollar amounts are known while others are unknown, do not record the
AmountUnknownIndicator element; instead, record the total of all known amounts in the
TotalSuspiciousAmountText element and provide an explanation for the unknown amounts in the
narrative.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "Amount unknown")
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
CumulativeTotalViolationAmountText
Description:
Cumulative amount (amount). This element identifies the cumulative amount (in whole U.S. dollars)
involved in the suspicious activity. The cumulative amount represents the total amount involved in all
FinCEN SARs filed on the suspicious activity, including the current FinCEN SAR being filed. This element
corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
31. Cumulative amount (only if continuing activity report is indicated)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
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Element Name:
CumulativeTotalViolationAmountText
Parent Element:
SuspiciousActivity
Element Restriction(s):
Conditionally Required. Record the CumulativeTotalViolationAmountText element if the FinCEN SAR
being filed is a continuing activity report (i.e. the ContinuingActivityReportIndicator element is recorded
with a "Y" value); otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: 1-15 numeric characters (without
leading zeros) denominated in whole U.S. Dollars. If the cumulative dollar amount is unknown because
all dollar amounts are unknown or no dollar amount is involved, enter zero ("0") and provide an
explanation in the narrative. If some dollar amounts are known while others are unknown, enter the
total of all known amounts and explain the nature of the unknown amounts in the narrative.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The value recorded contains one or more non-numeric characters.
•
The element is not recorded or does not contain a value and continuing activity report is
indicated.
•
The element is recorded with a value and continuing activity report is not indicated.
•
The amount recorded is less than the total amount recorded for
30000
Element Name:
NoAmountInvolvedIndicator
Description:
No amount involved (indicator). This element declares that there is no amount involved in the
suspicious activity. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
29b. No amount involved
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivity
Element Restriction(s):
Record this element when there is no amount involved in the suspicious activity; otherwise, do not
record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: "Y" (to indicate "No amount involved")
The batch submission will be rejected if any of the following conditions are true:
•
The value recorded is not equal to “Y” or not equal to null.
Y
Element Name:
SuspiciousActivityFromDateText
Description:
Date or start date of suspicious activity. This element identifies either the date on which the suspicious
activity occurred (in the event that the suspicious activity occurred on a single day) or the earliest date
of suspicious activity (in the event that that suspicious activity occurred on multiple days). This element
corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
30a. Date or date range (from) of suspicious activity
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. 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 the narrative. If the FinCEN SAR involves continuing activity, enter only the date range covered
by this FinCEN SAR. Record in the narrative the aggregated date range of all FinCEN SARs filed on the
continuing suspicious activity.
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Element Name:
Remarks:
Example:
SuspiciousActivityFromDateText
minOccurs:
1
maxOccurs:
1
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded for the element is not in the required format (YYYYMMDD).
•
The value recorded is greater than the date recorded for .
20171001
Element Name:
SuspiciousActivityToDateText
Description:
End date of suspicious activity (when different from the start date). This element identifies the mostrecent date of suspicious activity (in the event that that suspicious activity occurred on multiple days).
This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
30b. Date range (to) of suspicious activity
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivity
Element Restriction(s):
Record this element when the suspicious activity occurred on multiple days (in which case this element
will record the most-recent date of suspicious activity); otherwise, do not record this element.
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. 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 the narrative. If the FinCEN SAR involves continuing activity, enter only the date range covered
by this FinCEN SAR. Record in the narrative the aggregated date range of all FinCEN SARs filed on the
continuing suspicious activity.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (YYYYMMDD).
Value Restriction(s):
Remarks:
Example:
20171030
Element Name:
TotalSuspiciousAmountText
Description:
Total amount involved (amount). This element identifies the total amount (in whole U.S. dollars)
involved in the suspicious activity for the time period of the report. This element corresponds with the
following item(s):
•
minOccurs:
0
maxOccurs:
1
29. Amount involved in this report
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivity
Element Restriction(s):
Record this element when there is an amount involved in the FinCEN SAR and some or all of the dollar
amounts are known. Otherwise, do not record this element and instead, record either the
AmountUnknownIndicator element with a "Y" value if the entire amount is unknown, or the
NoAmountInvolvedIndicator element with a "Y" value if there is no amount involved in the FinCEN SAR.
If some dollar amounts are known while others are unknown, do not record the
AmountUnknownIndicator element; instead, record the total of all known amounts in the
TotalSuspiciousAmountText element and provide an explanation for the unknown amounts in the
narrative.
Value Restriction(s):
Remarks:
The value provided must adhere to the following requirements: 1-15 numeric characters (without
leading zeros) denominated in whole U.S. Dollars.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The value recorded contains one or more non-numeric characters.
•
The element is not recorded or does not contain a value and unknown or no amount involved
in not indicated.
•
The element is recorded with a value and unknown or no amount involved is indicated.
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Element Name:
TotalSuspiciousAmountText
minOccurs:
0
maxOccurs:
Example:
20000
Element Name:
SuspiciousActivityClassification
1
See SuspiciousActivityClassification Elements (below) for details.
4.7.1. SuspiciousActivityClassification Elements
Element Name:
SuspiciousActivityClassification
minOccurs:
1
maxOccurs:
99
Description:
Suspicious activity classification (header). This element is the container for information about the
specific type of suspicious activity.
The following sub-element is associated with this element:
Name
minOccurs
maxOccurs
OtherSuspiciousActivityTypeText
0
1
Simple
SuspiciousActivityTypeID
1
1
Simple
SuspiciousActivitySubtypeID
1
1
Category
Simple
This element corresponds with the following item(s):
•
•
•
•
•
•
•
•
•
•
•
32. Structuring (32a – 32e, 32z)
33. Terrorist financing (33a, 33z)
34. Fraud (34a – 34m, 34z)
35. Gaming activities (35a – 35d, 35z)
36. Money Laundering (36a – 36m, 36z)
37. Identification/Documentation (37a – 37f, 37z)
38. Other suspicious activities (38a – 38s, 38z)
39. Insurance (39a – 39f, 39z)
40. Securities/Futures/Options (40a – 40e, 40z)
41. Mortgage fraud (41a – 41e, 41z)
42. Cyber event (42a – 42b, 42z)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
SuspiciousActivity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
806
8
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Element Name:
OtherSuspiciousActivityTypeText
Description:
Suspicious activity other (description). This element identifies the other description of the suspicious
activity in the event that a type/category of activity applies (i.e. Structuring, Terrorist financing, etc.) but
none of the subtype options apply. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
32z - 42z. Other description of the suspicious activity subtype
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivityClassification
Element Restriction(s):
Conditionally Required. Record this element when the type of suspicious activity is recorded as "Other"
(i.e. contains any of the following codes:
1999,3999,4999,5999,6999,7999,8999,9999,10999,11999,12999); otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 50 characters or less
The batch submission will be accepted with warning if any of the following conditions are true:
•
The element is not recorded or does not contain a value and the subtype of suspicious
activity is equal to Other.
•
The element is recorded with a value but the subtype of suspicious activity is not equal to
Other.
other type of suspicious activity
description
Element Name:
SuspiciousActivitySubtypeID
Description:
Suspicious activity subtype (code). This element identifies the suspicious activity subtype, such as the
specific type of structuring or specific type of gaming activity. This element corresponds with the
subtype options associated with the following item(s):
•
•
•
•
•
•
•
•
•
•
•
minOccurs:
1
maxOccurs:
1
32. Structuring (32a – 32e, 32z)
33. Terrorist financing (33a, 33z)
34. Fraud (34a – 34m, 34z)
35. Gaming activities (35a – 35d, 35z)
36. Money Laundering (36a – 36m, 36z)
37. Identification/Documentation (37a – 37f, 37z)
38. Other suspicious activities (38a – 38s, 38z)
39. Insurance (39a – 39f, 39z)
40. Securities/Futures/Options (40a – 40e, 40z)
41. Mortgage fraud (41a – 41e, 41z)
42. Cyber event (42a – 42b, 42z)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivityClassification
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Record the subtype code from the lists below to identify the specific suspicious activity
subtype for the following:
o
Code
Structuring (1)
Description
111
Alters or cancels transaction to avoid BSA recordkeeping requirement
112
Alters or cancels transaction to avoid CTR requirement
106
Suspicious inquiry by customer regarding BSA reporting or recordkeeping
requirements
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Element Name:
SuspiciousActivitySubtypeID
minOccurs:
1
113
Transaction(s) below BSA recordkeeping threshold
114
Transaction(s) below CTR threshold
1999
Other
o
Code
Description
701
Known or suspected terrorist/terrorist organization
Other
o
Fraud (3)
Description
320
ACH
322
Advance fee
321
Business loan
301
Check
304
Consumer Loan
305
Credit/Debit Card
323
Healthcare/Public or private health insurance
308
Mail
309
Mass-marketing
324
Ponzi scheme
310
Pyramid scheme
325
Securities fraud
312
Wire transfer
3999
Other
o
Gaming activities (12)
Code
Description
1201
Chip walking
1202
Minimal gaming with large transactions
1203
Suspicious use of counter checks or markers
1204
Unknown source of chips
12999
Other
o
Code
1
Terrorist financing (7)
7999
Code
maxOccurs:
Money Laundering (8)
Description
801
Exchanges small bills for large bills or vice versa
824
Funnel account
820
Suspicious concerning the physical condition of funds
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Element Name:
SuspiciousActivitySubtypeID
minOccurs:
1
maxOccurs:
821
Suspicious concerning the source of funds
804
Suspicious designation of beneficiaries, assignees or joint owners
805
Suspicious EFT/wire transfers
822
Suspicious exchange of currencies
806
Suspicious receipt of government payments/benefits
807
Suspicious use of multiple accounts
808
Suspicious use of noncash monetary instruments
809
Suspicious use of third-party transactions (straw-man)
823
Trade Based Money Laundering/Black Market Peso Exchange
812
Transaction out of pattern for customer(s)
8999
Other
o
Code
Identification / Documentation (4)
Description
401
Changes spelling or arrangement of name
402
Multiple individuals with same or similar identities
403
Provided questionable or false documentation
409
Provided questionable or false identification
404
Refused or avoided request for documentation
405
Single individual with multiple identities
4999
Other
o
Code
1
Other suspicious activities (9)
Description
920
Account takeover
901
Bribery or gratuity
917
Counterfeit Instrument (other)
921
Elder financial exploitation
903
Embezzlement/theft/disappearance of funds
904
Forgeries
926
Human smuggling
927
Human trafficking
905
Identity theft
922
Little or no concern for product performance penalties, fees, or tax consequences
924
Misuse of position or self-dealing
907
Suspected public/private corruption (domestic)
908
Suspected public/private corruption (foreign)
909
Suspicious use of informal value transfer system
910
Suspicious use of multiple locations
925
Transaction with no apparent economic, business, or lawful purpose
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Element Name:
SuspiciousActivitySubtypeID
1
928
Transaction(s) involving foreign high risk jurisdiction
911
Two or more individuals working together
913
Unlicensed or unregistered MSB
9999
Other
o
Code
maxOccurs:
Insurance (5)
501
Excessive insurance
502
Excessive or unusual cash borrowing against policy/annuity
504
Proceeds sent to unrelated third party
505
Suspicious life settlement sales insurance (e.g., STOLI's, Viaticals)
506
Suspicious termination of policy or contract
507
Unclear or no insurable interest
5999
Other
Code
1
Description
o
Securities/Futures/Options (6)
Description
601
Insider trading
608
Market manipulation
603
Misappropriation
604
Unauthorized pooling
609
Wash trading
6999
Other
o
Mortgage fraud (10)
Code
Description
1005
Application fraud
1001
Appraisal fraud
1006
Foreclosure/Short sale fraud
1003
Loan Modification fraud
1007
Origination fraud
10999
Other
o
Remarks:
minOccurs:
Cyber event (11)
Code
Description
1101
Against financial institution(s)
1102
Against financial institution customer(s)
11999
Other
The batch submission will be rejected if any of the following conditions are true:
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Element Name:
SuspiciousActivitySubtypeID
minOccurs:
1
maxOccurs:
1
The element is not recorded.
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
The element contains a value that is not appropriate for the type of suspicious activity
recorded.
The element contains a value that has already been recorded for the Activity.
•
•
•
•
•
Example:
601
Element Name:
SuspiciousActivityTypeID
Description:
Suspicious activity type (code). This element identifies the type/category of suspicious activity, such as
Structuring, Terrorist financing, Fraud, etc. This element corresponds with the following item(s):
minOccurs:
1
maxOccurs:
1
32. Structuring
33. Terrorist financing
34. Fraud
35. Gaming activities
36. Money Laundering
37. Identification/Documentation
38. Other suspicious activities
39. Insurance
40. Securities/Futures/Options
41. Mortgage fraud
42. Cyber event
•
•
•
•
•
•
•
•
•
•
•
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
SuspiciousActivityClassification
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Record the type code from the list below to identify the specific suspicious activity type:
Remarks:
Example:
Code
Description
1
Structuring
7
Terrorist financing
3
Fraud
12
Gaming activities
8
Money Laundering
4
Identification / Documentation
9
Other suspicious activities
5
Insurance
6
Securities/Futures/Options
10
Mortgage fraud
11
Cyber event
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value not equal to one of the approved codes listed above.
6
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4.8. ActivityIPAddress Elements
Element Name:
ActivityIPAddress
minOccurs:
0
maxOccurs:
99
Description:
IP Address (header). This element is the container for information about IP address involved in the
suspicious activity. An explanation of the IP address must be recorded in the narrative as well.
The following sub-element is associated with this element:
Name
minOccurs
maxOccurs
ActivityIPAddressDateText
0
1
Simple
IPAddressText
1
1
Simple
ActivityIPAddressTimeStampText
0
1
Category
Simple
This element corresponds with the following item(s):
•
43. IP Address (if available)
o
43a. Date (YYYYMMDD)
o
43b. Timestamp (UCT) (HH:MM:SS)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Record this element when the IP address of the subject’s electronic internet based contact with the
financial institution is known; otherwise, do not record this element. If reporting an IP address in
connection with a cyber-event, do not record this element; instead, record the IP address within the
section.
Value Restriction(s):
Remarks:
Example:
n/a
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
20171101
166.123.216.61
Element Name:
ActivityIPAddressDateText
Description:
IP address (date). This element identifies the date of the activity associated with the reported IP address.
This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
43a. IP Address (Date)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityIPAddress
Element Restriction(s):
Record this element to identify the date of the first instance of the reported IP Address (if known);
otherwise, do not record this element.
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
Value Restriction(s):
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Element Name:
Remarks:
Example:
ActivityIPAddressDateText
minOccurs:
0
maxOccurs:
1
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (YYYYMMDD).
20171101
Element Name:
ActivityIPAddressTimeStampText
Description:
IP address (timestamp). This element identifies the UTC time of the first instance of the reported IP
address. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
43b. IP Address (Timestamp)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityIPAddress
Element Restriction(s):
Record this element to identify the Coordinated Universal Time (UCT) associated with the first instance
of the reported IP Address (if known); otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: UCT time must be in the format
"HH:MM:SS" where HH = hour (00-23), MM = minutes (00-59), and SS = second (00-59). Single digit
times must be prefaced by a zero.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (HH:MM:SS).
05:13:55
Element Name:
IPAddressText
Description:
IP address (text). This element identifies the IP address of the subject’s electronic internet based contact
with the financial institution. example, this may be the IP address used to log into the institution’s
online banking page or the IP address used to access an institution’s mobile application. This element
corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
43. IP Address (if available)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
ActivityIPAddress
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: If the IP address is IPv4, use a variation
of the format nnn.nnn.nnn.nnn (n = number) with periods between the segments. First set of numbers
must be values between 1-255 (inclusive); second, third and fourth set of numbers must be values
between 0-255 (inclusive).
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.
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (see Value Restrictions for
format requirements).
Remarks:
Example:
166.123.216.61
4.9. CyberEventIndicators Elements
Element Name:
CyberEventIndicators
Description:
minOccurs:
Cyber Event (header). This element is the container for information about cyber event involved in the
suspicious activity. An explanation of the cyber event must be recorded in the narrative as well.
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0
maxOccurs:
99
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Element Name:
CyberEventIndicators
minOccurs:
0
maxOccurs:
The following sub-element is associated with this element:
Name
99
minOccurs
maxOccurs
CyberEventDateText
0
1
Simple
CyberEventTimeStampText
0
1
Simple
CyberEventIndicatorsTypeCode
1
CyberEventTypeOtherText
0
EventValueText
1
1
1
1
Category
Simple
Simple
Simple
This element corresponds with the following item(s):
•
44. Cyber Event Indicators (44a-j, z)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Record this element when the suspicious activity involves one or more types of cyber events; otherwise,
do not record this element.
n/a
Value Restriction(s):
Remarks:
Example:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
20171101
1
11:05:45
166.123.216.61
Element Name:
CyberEventDateText
Description:
Cyber event (date). This element identifies the date of the first instance of the reported cyber event,
specifically, when reporting a Command and Control IP address or Suspicious IP Address. This element
corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
44a2. Date associated with Command and Control IP Address
44h2. Date associated with Suspicious IP Address
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
CyberEventIndicators
Element Restriction(s):
Record this element to identify the date associated with the following cyber events (if known);
otherwise, do not record this element:
•
Command and Control IP Address
•
Suspicious IP Address
The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
The batch submission will be rejected if any of the following conditions are true:
Value Restriction(s):
Remarks:
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Element Name:
CyberEventDateText
minOccurs:
0
maxOccurs:
1
maxOccurs:
1
The element is recorded for a cyber event type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (YYYYMMDD).
•
Example:
20171101
Element Name:
CyberEventIndicatorsTypeCode
minOccurs:
1
Description:
Cyber event indicator type (code). This element identifies the cyber event indicator type. This element
corresponds with the following item(s):
44a-j, z. Cyber Event Indicator
•
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
CyberEventIndicators
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Record the type of cyber event indicator from the list below:
Code
Remarks:
Example:
Description
1
Command and control IP address
2
Command and control URL/domain
3
Malware MD5, Malware SHA-1, or Malware SHA-256
4
Media Access Control (MAC) Address
5
Port
6
Suspicious e-mail address
7
Suspicious file name
8
Suspicious IP address
9
Suspicious URL/domain
10
Targeted system
999
Other
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded is invalid.
1
Element Name:
CyberEventTimeStampText
Description:
Cyber event (timestamp). This element identifies the UTC time of the first instance of the reported cyber
event, specifically, when reporting a Command and Control IP address or Suspicious IP Address. This
element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
44a2. Timestamp associated with Command and Control IP Address
44h2. Timestamp associated with Suspicious IP Address
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
CyberEventIndicators
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Element Name:
CyberEventTimeStampText
Element Restriction(s):
Record this element to identify the Coordinated Universal Time (UCT) associated with the first instance
of the following cyber events (if known); otherwise, do not record this element:
•
Command and Control IP Address
•
Suspicious IP Address
Value Restriction(s):
Remarks:
Example:
minOccurs:
0
maxOccurs:
1
The value provided must adhere to the following requirements: UCT time must be in the format
"HH:MM:SS" where HH = hour (00-23), MM = minutes (00-59), and SS = second (00-59). Single digit
times must be prefaced by a zero.
The batch submission will be rejected if any of the following conditions are true:
•
The element is recorded for a cyber event type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
•
The value recorded for the element is not in the required format (HH:MM:SS).
11:05:45
Element Name:
CyberEventTypeOtherText
Description:
Cyber event other (description). This element identifies the description of the other type of reported
cyber event. This element corresponds with the following item(s):
•
minOccurs:
0
maxOccurs:
1
44z2. Text description of other value
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
CyberEventIndicators
Element Restriction(s):
Conditionally Required. Record this element when the type of cyber event is recorded as "Other" (i.e.
contains the value "11" code); otherwise, do not record this element.
Value Restriction(s):
Remarks:
Example:
The value provided must adhere to the following requirements: 50 characters or less
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The element is not recorded or does not contain a value and the
is equal to “11” Other.
•
The element is recorded with a value and the is not equal
to “11” Other.
Other description
Element Name:
EventValueText
Description:
Cyber event (value). This element identifies the event value associated with the reported cyber event.
This element corresponds with the following item(s):
•
minOccurs:
1
maxOccurs:
1
44a-j, z. Cyber Event Indicator
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
CyberEventIndicators
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 4000 characters or less; must be in the
following format based on these specific types of cyber events:
•
Command and Control/Suspicious IP Addresses: If the IP address is IPv4, use a variation of the
format nnn.nnn.nnn.nnn (n = number) with periods between the segments. First set of
numbers must be values between 1-255 (inclusive); second, third and fourth set of numbers
must be values between 0-255 (inclusive). 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.
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Element Name:
EventValueText
•
•
•
1
maxOccurs:
1
URL/Domain names: Must contain at least one period, no spaces, cannot begin or end with a
dash.
Media Access Control (MAC) Addresses: Must be in the format XX:XX:XX:XX:XX:XX
Email Addresses: Must contain @ symbol and at least one period following the @ symbol.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The element is not recorded or does not contain.
•
The value recorded is not valid based on the type of cyber event (see Value Restrictions for
format requirements).
Remarks:
Example:
4.10.
minOccurs:
166.123.216.61
Assets Elements
Element Name:
Assets
minOccurs:
0
maxOccurs:
31
Description:
Asset (header). This element is the container for information about asset involved in the suspicious
activity, specifically the product type, instrument type, and/or payment mechanism.
The following sub-elements are associated with this element:
Name
minOccurs
maxOccurs
AssetSubtypeID (Items 45a-t, z / 46a-i, z)
1
1
Simple
OtherAssetSubtypeText (Items 45z, 46z)
0
1
Simple
AssetTypeID (Items 45, 46)
1
Category
1
Simple
This element corresponds with the following item(s):
•
•
45. Product type(s) involved in suspicious activity (45a-t, z)
46. Instrument type(s)/payment mechanism(s) involved in suspicious activity (46a-I, z)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Record this element when a product type, instrument type, and/or payment mechanism, was involved in
the suspicious activity; otherwise, do not record this element.
If multiple product/instrument types and/or payment mechanisms were involved in the suspicious
activity, record a separate instance of this element to identify each one that applies. The following table
describes the min/max number of occurrences this element may be recorded for item 45 (product type)
and item 46 (instrument type/payment mechanism):
Sub-types associated with the following types:
min-max
Item 45. Product type (AssetTypeID=5)
0-21
Item 46. Instrument type/Payment mechanism (AssetTypeID=6)
0-10
Total
0-31
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
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Element Name:
Assets
minOccurs:
Example:
2
5
Element Name:
AssetSubtypeID
Description:
Asset subtype (code). This element identifies the specific type of asset involved in the suspicious activity,
such as Bonds/Notes if a product type is involved, or Bank/cashier’s check if an instrument/payment
mechanism is involved. This element corresponds with the following item(s):
minOccurs:
0
maxOccurs:
31
1
maxOccurs:
1
45a-t, z. Product type(s) involved in suspicious activity
46a-i, z. Instrument type(s)/payment mechanism(s) involved in suspicious activity
•
•
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Assets
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Item 45. Product type (AssetTypeID=5)
Code
Description
2
Bonds/Notes
3
Commercial mortgage
4
Commercial paper
5
Credit card
6
Debit card
46
Deposit Account
7
Forex transactions
8
Futures/Options on futures
9
Hedge fund
11
Home equity line of credit
10
Home equity loan
12
Insurance/Annuity products
47
Microcap securities
13
Mutual fund
14
Options on securities
16
Prepaid access
17
Residential mortgage
18
Security futures products
19
Stocks
20
Swap, hybrid, or other derivative
30
Other
•
Code
31
Item 46. Instrument type/Payment mechanism (AssetTypeID=6)
Description
Bank/Cashier's check
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Element Name:
Remarks:
Example:
AssetSubtypeID
32
Foreign currency
33
Funds transfer
34
Gaming instruments
35
Government payment
36
Money orders
37
Personal/Business check
38
Travelers checks
39
U.S. Currency
41
Other
minOccurs:
1
maxOccurs:
1
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value not equal to one of the approved codes listed above.
•
The element contains a value that is not appropriate for the type of asset recorded.
•
The element contains a value that has already been recorded for the Activity.
2
Element Name:
AssetTypeID
minOccurs:
1
maxOccurs:
1
Description:
Asset type (code). This element identifies the type/category of assets, specifically whether it is
associated with a product type or instrument/payment mechanism. This element corresponds with the
following item(s):
45. Product type(s) involved in suspicious activity
46. Instrument type(s)/payment mechanism(s) involved in suspicious activity
•
•
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
Assets
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
Remarks:
Example:
Code
Description
5
Product type(s) involved in suspicious activity
6
Instrument type(s)/payment mechanism(s) involved in suspicious activity
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value not equal to one of the approved codes listed above.
5
Element Name:
OtherAssetSubtypeText
Description:
Asset other (description). This element identifies the description of the other type of reported asset
subtype. This element corresponds with the following item(s):
•
•
minOccurs:
0
maxOccurs:
1
45z. Product type(s) (other description)
46z. Instrument type(s)/payment mechanism(s) (other description)
Please refer to Attachment C for additional information regarding the above item(s).
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Element Name:
OtherAssetSubtypeText
Attribute(s)
n/a
Parent Element:
Assets
Element Restriction(s):
Conditionally Required. Record this element to provide a description of the other product/instrument
type/payment mechanism when the element contains the values "30" or "41";
otherwise, do not record this element.
Value Restriction(s):
0
maxOccurs:
1
The value provided must adhere to the following requirements: 50 characters or less.
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The element is not recorded or does not contain a value and Other is indicated for the
element.
•
The element is recorded with a value and Other is not indicated for the
element.
Remarks:
Example:
4.11.
minOccurs:
other instrument type description
AssetsAttribute Elements
Element Name:
AssetsAttribute
Description:
minOccurs:
0
maxOccurs:
396
Asset Attribute (header). This element is the container for information about the asset attribute involved
in the suspicious activity, whether it be a type of commodity, product/instrument, market where traded,
and/or CUSIP number.
The following sub-elements are associated with this element:
Name
minOccurs
maxOccurs
1
1
AssetAttributeDescriptionText (Items 47-50)
AssetAttributeTypeID (Items 47-50)
1
Category
Simple
1
Simple
This element corresponds with the following item(s):
•
•
•
•
47. Commodity type (if applicable)
48. Product/Instrument description (if needed)
49. Market where traded
50. CUSIP number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Record this element when the suspicious activity involves any of the following: Commodity type,
product/instrument, market where traded, and/or CUSIP number; otherwise, do not record this element.
No more than 99 occurrences of each asset attribute type mentioned above may be recorded for the
FinCEN SAR:
Attribute types
min-max
Item 47. Commodity type (if applicable)
0-99
Item 48. Product/Instrument description (if needed)
0-99
Item 49. Market where traded
0-99
Item 50. CUSIP number
0-99
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Element Name:
AssetsAttribute
minOccurs:
0
maxOccurs:
Total
0-396
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
396
Commodity type
description
2
Element Name:
AssetAttributeDescriptionText
Description:
Asset attribute other (description). This element provides a description of the reported asset attribute
involved in the suspicious activity. This element corresponds with the following item(s):
•
•
•
•
minOccurs:
1
maxOccurs:
1
47. Commodity type (if applicable)
48. Product/Instrument description (if needed)
49. Market where traded
50. CUSIP number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
AssetsAttribute
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
•
Commodity type description: 50 characters or less
•
Instrument/Product description: 50 characters or less
•
Market where traded: 3-5 letter code for the market where a recorded commodity was
traded. Use only the ISO 10383 Exchange/Market Identifier Codes (MIC) found at
http://www.iso15022.org/MIC/homepageMIC.htm.
•
CUSIP Number: 12 characters or less to identify the CUSIP number of a recorded securities
product (such as stocks and bonds) involved in the suspicious.
Remarks:
Example:
The batch submission will be accepted with warnings if any of the following conditions are true:
•
The element is not recorded or the element is recorded but with no value.
•
The value recorded is not valid based on the type of asset attribute (see Value Restrictions for
format requirements).
Commodity type description
Element Name:
AssetAttributeTypeID
Description:
Asset attribute type (code). This element identifies the type/category of asset attribute, specifically
whether it is a type of commodity, product/instrument, market where traded, or CUSIP number. This
element corresponds with the following item(s):
•
•
•
•
minOccurs:
1
maxOccurs:
1
47. Commodity type (if applicable)
48. Product/Instrument description (if needed)
49. Market where traded
50. CUSIP number
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
n/a
Parent Element:
AssetsAttribute
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Element Name:
AssetAttributeTypeID
Element Restriction(s):
Required. This element must be recorded if the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
Code
2
1
maxOccurs:
1
Description
Commodity type
3
Product/Instrument type
4
Market where traded
1
CUSIP number
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is recorded but without a value (i.e. the value is null).
•
The element contains a value not equal to one of the approved codes listed above.
Remarks:
Example:
4.12.
minOccurs:
2
ActivityNarrativeInformation Elements
Element Name:
ActivityNarrativeInformation
minOccurs:
1
maxOccurs:
5
Description:
Narrative (header). This element is the container for information about narrative description associated
with the FinCEN SAR.
The following sub-elements are associated with this element:
Name
minOccurs
maxOccurs
1
1
ActivityNarrativeSequenceNumber
ActivityNarrativeText
1
1
Category
Simple
Simple
This element corresponds with the following item(s):
o
Part V. Suspicious Activity Report – Narrative
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s)
The following attributes must be recorded for this element:
Name
Description
SeqNum
The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Parent Element:
Activity
Element Restriction(s):
Required. This element must be recorded.
Value Restriction(s):
n/a
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded.
•
The element is missing a “SeqNum” attribute.
•
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example:
1
Text narrative text
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Element Name:
ActivityNarrativeSequenceNumber
Description:
Narrative (sequence number). This element identifies the sequence in which the narrative text should be
constructed in the event that multiple ActivityNarrativeInformation element blocks are needed to record
the entire narrative.
Attribute(s)
minOccurs:
1
maxOccurs:
For example, if the narrative text is 5,000 characters in length, there should be two instances of the
ActivityNarrativeInformation element block, where the first instance contains
ActivityNarrativeSequenceNumber “>1<” followed by the first 4,000 characters of the narrative
description in the ActivityNarrativeText element; in order to record the remaining 1,000 characters of
the narrative description, a second instance of the ActivityNarrativeInformation element block should be
recorded where the ActivityNarrativeSequenceNumber is “>2<” followed by the remaining 1,000
characters of the narrative description in the ActivityNarrativeText element.
n/a
Parent Element:
ActivityNarrativeInformation
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements:
Remarks:
Example:
1
Code
Description
1
First block of narrative text (character set 1-4000)
2
Second block of narrative text (character set 4001-8000, if needed)
3
Third block of narrative text (character set 8001-12000, if needed)
4
Fourth block of narrative text (character set 12001-16000, if needed)
5
Fifth block of narrative text (character set 16001-20000, if needed)
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
•
The value recorded is not equal to a valid code.
•
The element contains a value that has already been recorded for the Activity.
1
Element Name:
ActivityNarrativeText
Description:
Narrative (description). This element records the narrative description associated with the suspicious
activity. The narrative must provide a clear, complete, and concise description of the activity, including
what was unusual or irregular that caused suspicion. This description should include data from Parts I
through III only when that data are necessary for a complete understanding of the suspicious activity.
Filers should include any other information necessary to explain the nature and circumstances of the
suspicious activity
Attribute(s)
minOccurs:
1
maxOccurs:
n/a
Parent Element:
ActivityNarrativeInformation
Element Restriction(s):
Required. This element must be recorded when the parent element is recorded.
Value Restriction(s):
The value provided must adhere to the following requirements: 4000 characters or less
Remarks:
The batch submission will be rejected if any of the following conditions are true:
•
The element is not recorded or does not contain a value.
Example:
1
Text narrative text
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5. Party Elements by Party Type
The element is comprised of various elements and sub-elements that apply to specific party types (i.e.
Transmitter, financial institution where activity occurred, etc.). The chart below describes at a high level the party
elements that apply to each party type.
Activity party type code definitions
35 = Transmitter | 37 = Transmitter Contact | 30 = Filing Institution | 8 = Contact Office |18 = LE Contact Agency
19 = LE Contact Name | 34 = Financial Institution Where Activity Occurred
46 = Branch Where Activity Occurred | 33 = Subject 41 = Financial Institution Where Account is Held
Element name
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35
●
●
37
●
●
30
●
●
8
●
●
18
●
●
19
●
●
34
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
46
33
●
●
●
●
●
●
●
41
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
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Element name
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35
●
37
30
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
8
●
●
●
●
18
19
●
●
●
●
34
46
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
33
●
●
●
●
●
●
●
●
●
●
●
●
●
●
41
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
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Element name
35
●
37
●
30
●
8
●
18
●
19
●
34
●
●
●
●
●
●
●
●
●
46
●
●
●
●
●
●
●
●
33
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
41
●
●
●
●
●
●
●
●
●
●
●
●
●
●
●
5.1. Transmitter Party Record Example
Party Type
Transmitter
35
35
L
Transmitter legal name
Transmitter city
US
VA
Transmitter street address
22113
7217894455
458985215
4
PBSA1234
28
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minOccurs:
1
maxOccurs:
1
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Party Type
Transmitter
minOccurs:
1
maxOccurs:
1
1
maxOccurs:
1
5.2. Transmitter Contact Party Record Example
Party Type
Transmitter Contact
37
37
L
Transmitter contact legal name
minOccurs:
5.3. Filing Institution Party Record Example
Party Type
Filing Institution
30
30
7
L
Filer name
DBA
Alternate name
Rockville
US
MD
123 Viers Mill Road
20905
125478965
2
5558789654
10
451256558
29
535
5
529
5
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minOccurs:
1
maxOccurs:
1
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5.4. Designated Contact Office Party Record Example
Party Type
Designated Contact Office
minOccurs:
1
maxOccurs:
8
8
L
Designated contact office
1234
4157653838
1
5.5. Law Enforcement Agency Party Record Example
Party Type
Law Enforcement Agency
18
18
L
LE Contact Agency
minOccurs:
0
maxOccurs:
1
5.6. Law Enforcement Name Party Record Example
Party Type
Law Enforcement Name
minOccurs:
0
maxOccurs:
19
19
20171105
L
LE Contact Name
5432
7039051234
1
5.7. Financial Institution Where Activity Occurred Party Record Example
Party Type
Financial Institution Where Activity Occurred
34
34
15000
Y
Y
4
L
Union Bank of California
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minOccurs:
1
maxOccurs:
99
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Party Type
Financial Institution Where Activity Occurred
minOccurs:
1
maxOccurs:
99
maxOccurs:
99
DBA
Doing Business As Name
Y
Y
987 Rocky Road
Y
Y
458789856
2
5589887789
10
4578958658
29
533
5
5999
5
other S/F institution
description
46
…
5.8. Branch Where Activity Occurred Party Record Example
Party Type
Branch Where Activity Occurred
46
46
Y
Cityville
US
VA
123 Address Way
547898856
445564615654
14
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minOccurs:
0
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Party Type
Branch Where Activity Occurred
minOccurs:
0
maxOccurs:
99
minOccurs:
1
maxOccurs:
999
5.9. Subject Party Record Example
Party Type
Subject
33
33
Y
Y
Y
19801025
L
Mann
Janice
AKA
Janda
AKA
Jan
Y
Y
Y
Y
Y
6194760276
R
5584
6589784589
W
Y
US
CA
Student ID
660623559
999
Y
7548
Mechanic
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Party Type
Subject
minOccurs:
1
maxOccurs:
999
[email protected]
E
janda.org
U
Y
458789856
7
41
…
5.10.
Financial Institution Where Account is Held Party Record Example
Party Type
Financial Institution Where Account is Held
41
41
Y
458789856
4
1502417873
Y
5
5477887896
Y
5
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minOccurs:
0
maxOccurs:
99
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6. FinCEN SAR XML Acknowledgement Format
The FinCEN SAR XML batch acknowledgement file defined below is provided in XML format. The acknowledgement
file will contain a BSA Identifier and any corresponding acknowledgement errors associated with each FinCEN SAR
element received in the batch submission. Please visit
https://www.fincen.gov/sites/default/files/schema/base/EFL_BatchAcknowledgementSchema.xsd to access the FinCEN
XML 2.0 batch acknowledgement schema file.
6.1. XML File Structure
6.1.1. XML declaration/prolog
The XML declaration appears on the first line of the acknowledgement file.
Element Name:
?xml
minOccurs:
1
maxOccurs:
1
Description:
XML declaration/prolog. This is the XML declaration which specifies the XML version and character
encoding used in the file.
Attribute(s):
version. The version number of the XML. The value recorded will be “1.0”
Parent Element:
n/a
Element Restriction(s)
This declaration will always be recorded on the first line of the file.
Value Restriction(s):
The value provided will be:
encoding. The character encoding used for the XML. The value recorded will be “UTF-8”
•
Remarks:
none
Example:
6.1.2. EFilingBatchXML
The element is the first element recorded in the file and is considered the root element.
Element Name:
EFilingBatchXML
minOccurs:
1
maxOccurs:
1
Description:
Batch acknowledgement (header). This is the container for the contents of the batch acknowledgement
file.
This element is parent to the following sub-elements:
EFilingSubmissionXML *
NOTE: Elements marked with an asterisk * contain sub-elements.
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Attribute(s):
SeqNum (this is a sequential number assigned by FinCEN to identify the corresponding element in the
associated batch file)
StatusCode (this will have a value of “A” to indicate “Acknowledged”)
Parent Element:
n/a (this is the root element in the acknowledgment file)
Element Restriction(s)
This element will always be recorded.
Value Restriction(s):
n/a
Remarks:
n/a
Example:
6.1.3. EFilingSubmissionXML
The element directly follows the root element. This element is for
FinCEN use only.
Element Name:
EFilingSubmissionXML
minOccurs:
1
maxOccurs:
1
Description:
Submission acknowledgement (header). This is the container for all FinCEN SAR elements
recorded in the associated batch submission.
This element is parent to the following sub-elements:
EFilingActivityXML *
NOTE: Elements marked with an asterisk * contain sub-elements.
Attribute(s):
xmlns (this will always be www.fincen.gov/base)
SeqNum (this is a sequential number assigned by FinCEN to identify the corresponding element in the
associated batch file)
StatusCode (this will have a value of “A” to indicate “Acknowledged”)
Parent Element:
EFilingBatchXML
Element Restriction(s):
This element will always be recorded.
Value Restriction(s):
n/a
Remarks:
This element is for FinCEN use only.
Example:
6.1.4. EFilingActivityXML
Each element in the batch acknowledgement file corresponds with each FinCEN SAR
element recorded in the original batch submission along with the sequence number (SeqNum) attribute value.
Element Name:
EFilingActivityXML
minOccurs:
1
maxOccurs:
unbounded
Description:
Activity acknowledgement (header). This is the container for acknowledgement information for each
FinCEN SAR element recorded in the associated batch submission.
This element is parent to the following sub-elements:
BSAID
EFilingActivityErrorXML *
NOTE: Elements marked with an asterisk * contain sub-elements.
Attribute(s):
SeqNum (this sequential number matches the value recorded in the associated batch submission)
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Parent Element:
EFilingSubmissionXML
Value Restriction(s):
n/a
Remarks:
none
Example:
31000055053784
Element Name:
BSAID
minOccurs:
1
maxOccurs:
1
Description:
Activity acknowledgement BSA Identifier (text). This element identifies the BSA Identifier (BSA ID)
assigned by FinCEN to the FinCEN SAR document.
Attribute(s):
n/a
Parent Element:
EFilingActivityXML
Value Restriction(s):
14 characters (numeric only)
Remarks:
none
Example:
31000055053784
6.1.5. EFilingActivityErrorXML
There will be at least one element for each element in the batch
acknowledgement file.
Element Name:
EFilingActivityErrorXML
minOccurs:
1
maxOccurs:
unbounded
Description:
Activity acknowledgement error (header). This is the container for error information generated during
processing of the associated batch submission related to the FinCEN SAR activity.
This element is parent to the following sub-elements:
ErrorContextText
ErrorElementNameText
ErrorLevelText
ErrorText
ErrorTypeCode
Attribute(s):
SeqNum (this is a sequential number assigned by FinCEN)
Parent Element:
EFilingActivityXML
Value Restriction(s):
n/a
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
EFilingBatchXML/Activity[1]/Party[25]/PartyIdentification[49]/PartyIdentifi
cationNumberText
PartyIdentificationNumberText
WARN
The value recorded for the EIN or SSN/ITIN is an invalid number
string.
C21
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EFilingBatchXML/Activity[1]/Party[78]/PartyName[84]/RawIndividualFirstN
ame
RawIndividualFirstName
WARN
The element is not recorded or does not contain a value for an individual Subject
and unknown is not indicated.
C4
Element Name:
ErrorContextText
minOccurs:
Description:
Acknowledgement error type (text). This element identifies the element location (within the associated
batch submission) that triggered the error by identifying the name and sequence number of the
element’s element.
Attribute(s):
n/a
Parent Element:
EFilingActivityErrorXML
Value Restriction(s):
1-4000 characters
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
EFilingBatchXML/Activity[1]/Party[25]/PartyIdentification[49]/PartyIdentificationNum
berText
Element Name:
ErrorElementNameText
Description:
Element acknowledgement error association (text). This element identifies the element name from the
associated batch submission that triggered the error.
Attribute(s):
n/a
Parent Element:
EFilingActivityErrorXML
Value Restriction(s):
1-512 characters
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
PartyIdentificationNumberText
Element Name:
ErrorLevelText
Description:
Acknowledgement error severity level (text). This element identifies the level of severity associated with
the error.
Attribute(s):
n/a
Parent Element:
EFilingActivityErrorXML
Value Restriction(s):
1-50 characters
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
WARN
Element Name:
ErrorText
minOccurs:
minOccurs:
minOccurs:
FinCEN SAR XML Schema User Guide (version 1.5 | July 2020)
0
0
0
0
maxOccurs:
maxOccurs:
maxOccurs:
maxOccurs:
1
1
1
1
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Description:
Acknowledgement error description (text). This element identifies the description of the error.
Attribute(s):
n/a
Parent Element:
EFilingActivityErrorXML
Value Restriction(s):
1-525 characters
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
The value recorded for the EIN or SSN/ITIN is an invalid number string.
Element Name:
ErrorTypeCode
Description:
Acknowledgement error type (code). This element identifies the code associated with the error.
Attribute(s):
n/a
Parent Element:
EFilingActivityErrorXML
Value Restriction(s):
1-50 characters
Remarks:
If there are no errors identified for the FinCEN SAR activity, then the element
will be recorded with a self-closing tag (e.g. ) and this element
will not be recorded.
Example:
C4
minOccurs:
0
maxOccurs:
1
6.2. Acknowledgement XML Example
The following is a sample FinCEN SAR acknowledgement XML generated by FinCEN and delivered to the batch filer.
File type
FinCEN SAR XML Batch Acknowledgement (Sample)
Example:
31000055053784
EFilingBatchXML/Activity[1]/Party[25]/PartyIdentification[49]/Pa
rtyIdentificationNumberText
PartyIdentificationNumberText
WARN
The value recorded for the EIN or SSN/ITIN is an invalid number
string.
C21
EFilingBatchXML/Activity[1]/Party[78]/PartyName[84]/RawIndivi
dualFirstName
RawIndividualFirstName
WARN
The element is not recorded or does not contain a value for an
individual Subject and unknown is not indicated.
C4
31000055053785
31000055053786
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Notes:
The sample above consists of three (3) FinCEN SAR activities based on the original FinCEN SAR batch submission:
•
•
•
•
•
Each FinCEN SAR from the original batch submission is associated with a element
Each FinCEN SAR receives a unique BSA Identifier (BSA ID)
FinCEN SAR (BSA ID: 31000055053784) contains two errors (C21 & C4)
FinCEN SAR (BSA ID: 31000055053785) contains no errors
FinCEN SAR (BSA ID: 31000055053786) contains no errors
7. Attachment A – Error Descriptions
The following table lists the errors that your batch may receive as a result of missing or invalid data formatting.
FinCEN strongly encourages that filers first test their XML batch files for schema compliance using the schemas
available at www.fincen.gov/base. Your batch file should pass schema validation before you attempt to submit to
FinCEN. As a result, this table does not include all possible schema validation errors, as these will be handled by your
XML software during testing. Your batch file must pass schema validation before attempting to submit to FinCEN via
BSA E-Filing; otherwise, it will be rejected.
Error Level
Fatal
Batch rejection
These errors are related to the batch format and must be resolved before attempting to resubmit the batch.
Primary Warning
Batch acceptance with warning(s) classified as primary data errors
These errors violate electronic filing requirements or report instructions and so degrade FinCEN SAR data quality that they must be
corrected (along with warning errors) as a correction/amendment Error codes marked with an asterisk (*) are primary warnings.
Warning
Batch acceptance with warning(s) classified as secondary data errors.
These errors that violate electronic filing requirements or report instructions but have a lesser impact on FinCEN SAR data quality.
7.1. Miscellaneous Errors
These errors can occur throughout the batch file:
Code
Error Text
Severity
Associated Element(s)
Form Reference
A0
The XML declaration/prolog is not
recorded with the required values or
it is not recorded on the first line of
the batch file.
The element is not recorded for the
required party type.
The critical element is not recorded
for the required party type.
The element is recorded for an
inappropriate party type.
The critical element is not recorded.
Fatal
Misc.
Misc.
Warning
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
The element exceeds the maximum
occurrence threshold.
The element is missing a “SeqNum”
attribute
The element contains a “SeqNum”
attribute with a duplicate or invalid
value
Fatal
Misc.
Misc.
A1
A2
A3
A4
A5
A6
A7
A8
The element is not recorded.
Warning
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
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Code
A9
A10
A11
A12
A13
A14
A15
A16
A17
A18
A19
A20
A21
A23
A24
A25
A27
A29
A30
Error Text
One or more of the attributes are
missing, incorrectly formatted, or
contain an invalid value
The reported total count of all
activities in the batch does not match
the actual count.
The reported sum of all total
amounts recorded in the batch does
not match the actual amount.
The reported count of the total
number of parties in the batch does
not match the actual count.
The reported count of activities
containing an attachment does not
match the actual count.
The reported count of attachments
does not match the actual count.
Cannot continue processing the
submitted file because of previous
errors encountered.
One, or more, invalid characters were
present in the submitted file.
The namespace prefix for the
element is invalid.
Unexpected element sequence. The
element is not allowed at this
location.
Schema validation failure. The XML
file does not conform to the defined
schema located at
https://www.fincen.gov/base/EFL_SA
RXBatchSchema.xsd.
This submission cannot be accepted
because it contains significant errors.
Please fix and resubmit the file.
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.
The value recorded is not appropriate
for the associated party type.
Unknown is indicated for data that is
provided.
Unknown is indicated for data that is
provided and unknown is not a valid
response.
The element recorded conflicts with
one or more recorded elements.
The value recorded does not contain
an associated type.
The value is missing or invalid.
Severity
Associated Element(s)
Form Reference
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Warning
Misc.
Misc.
Fatal
Misc.
Misc.
Warning
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
Fatal
Misc.
Misc.
7.2. Document Errors
These errors can occur at the FinCEN SAR document level:
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Code
Error Text
Severity
Associated Element(s)
Form Reference
B0
The value recorded is not equal to “Y”
or not equal to null.
The element is not recorded.
Fatal
All indicator elements
Misc.
Fatal
PartyNameTypeCode
Misc.
Fatal
PartyNameTypeCode
Misc.
Fatal
PartyIdentificationTypeCode
Misc.
Fatal
PartyIdentificationTypeCode
Misc.
B1
B2
B3
B4
The element is recorded but with no
value (i.e. the value is null).
The element contains an invalid code.
Fatal
B6
B9
The element is not recorded.
Fatal
PartyIdentificationTypeCode
Misc.
B11
The element is recorded but with no
value (i.e. the value is null).
The element contains an invalid code.
Fatal
ActivityPartyTypeCode
Misc.
B7
B10
B12
B13
B14
B15
B16*
B17*
B18*
B19*
B20
B21
The element is recorded but with no
value (i.e. the value is null).
The element is not recorded.
The element is not recorded.
The element is recorded but none of
the following sub-elements are
recorded with a “Y” value:
InitialReportIndicator,
CorrectsAmendsPriorReportIndicator,
and
ContinuingActivityReportIndicator.
InitialReportIndicator contains a “Y”
value and either/both of the
following elements also contain a “Y”
value:
CorrectsAmendsPriorReportIndicator,
ContinuingActivityReportIndicator.
The element is not recorded and the
filing type is corrects/amends prior
report and/or continuing activity
report.
The element is recorded but without
a value (i.e. the value is null).
Fatal
Fatal
PartyNameTypeCode
Misc.
The element is recorded with a value
that is not approved for the
associated party type (see Value
Restrictions for more information).
The element is not recorded and the
contains a value.
The element contains an invalid code.
B5
Fatal
PartyNameTypeCode
PartyIdentificationTypeCode
ActivityPartyTypeCode
Misc.
Misc.
Misc.
Fatal
ActivityPartyTypeCode
Misc.
Fatal
ActivityAssociation
1. Type of Filing
Fatal
ActivityAssociation
1. Type of Filing
Warning
ActivityAssociation
1. Type of Filing
Warning
EFilingPriorDocumentNumber
Warning
EFilingPriorDocumentNumber
The element is recorded with a valid
value but the filing type is not
corrects/amends prior report and/or
continuing activity report.
The value recorded does not equal
14 numeric characters.
Warning
EFilingPriorDocumentNumber
Warning
EFilingPriorDocumentNumber
The value recorded contains one or
more non-numeric characters.
The element is not recorded or does
not contain a value and unknown or
no amount involved is not indicated.
Warning
TotalSuspiciousAmountText
Warning
TotalSuspiciousAmountText
01e. Type of Filing: e. Prior
report BSA Identification
Number if items 1b or 1c
are checked
01e. Type of Filing: e. Prior
report BSA Identification
Number if items 1b or 1c
are checked
01e. Type of Filing: e. Prior
report BSA Identification
Number if items 1b or 1c
are checked
01e. Type of Filing: e. Prior
report BSA Identification
Number if items 1b or 1c
are checked
29. Amount involved in this
report
29. Amount involved in this
report
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Code
Severity
Associated Element(s)
Form Reference
Warning
SuspiciousActivityFromDateTe
xt
30a. Date or date range of
suspicious activity (From)
Warning
SuspiciousActivityFromDateTe
xt
30a. Date or date range of
suspicious activity (From)
Warning
SuspiciousActivityFromDateTe
xt
30a. Date or date range of
suspicious activity (From)
Warning
SuspiciousActivityToDateText
30b. Date or date range of
suspicious activity (To)
Warning
CumulativeTotalViolationAmo
untText
CumulativeTotalViolationAmo
untText
31. Cumulative amount
Warning
CumulativeTotalViolationAmo
untText
31. Cumulative amount
Warning
CumulativeTotalViolationAmo
untText
31. Cumulative amount
B31
The value recorded for the element is
not in the required format
(YYYYMMDD).
The value recorded is greater than
the date recorded for
SuspiciousActivityToDateText.
The value recorded for the element is
not in the required format
(YYYYMMDD).
The value recorded contains one or
more non-numeric characters.
The element is not recorded or does
not contain a value and continuing
activity report is indicated.
The element is recorded with a value
and continuing activity report is not
indicated.
The cumulative amount recorded is
less than the total amount recorded
for TotalSuspiciousAmountText.
The element is not recorded.
Fatal
SuspiciousActivity
B32
The element is not recorded.
Fatal
B33
The element is not recorded.
Fatal
SuspiciousActivityClassificatio
n
SuspiciousActivityTypeID
B34
The element is recorded but without
a value (i.e. the value is null).
Fatal
SuspiciousActivityTypeID
B35
The element contains an invalid code.
Fatal
SuspiciousActivityTypeID
B36
The element is not recorded.
Fatal
SuspiciousActivitySubtypeID
B37
The element is recorded but without
a value (i.e. the value is null).
Fatal
SuspiciousActivitySubtypeID
B38
The element contains an invalid code.
Fatal
SuspiciousActivitySubtypeID
B39
The element contains a value that is
not appropriate for the type of
suspicious activity recorded.
Fatal
SuspiciousActivitySubtypeID
B40
The element is not recorded or does
not contain a value and the subtype
of suspicious activity is equal to
Other.
Warning
OtherSuspiciousActivityTypeT
ext
32-42. Suspicious Activity
Information
32-42. Suspicious Activity
Classification
32-42. Suspicious Activity:
Type (ACH, Ponzi scheme,
Chip walking, etc.)
32-42. Suspicious Activity:
Type (ACH, Ponzi scheme,
Chip walking, etc.)
32-42. Suspicious Activity:
Type (ACH, Ponzi scheme,
Chip walking, etc.)
32a-42z. Suspicious
Activity: Subtype
(Structuring, Terrorist
financing, Cyber event, etc.)
32a-42z. Suspicious
Activity: Subtype
(Structuring, Terrorist
financing, Cyber event, etc.)
32a-42z. Suspicious
Activity: Subtype
(Structuring, Terrorist
financing, Cyber event, etc.)
32a-42z. Suspicious
Activity: Subtype
(Structuring, Terrorist
financing, Cyber event, etc.)
32z-42z. Suspicious
Activity: Other Type
Description
B22*
B23*
B24*
B25
B26*
B27*
B28*
B29
B30
Error Text
The element is recorded with a value
while unknown and/or no amount
involved is indicated.
The element is not recorded or does
not contain a value.
Warning
Warning
FinCEN SAR XML Schema User Guide (version 1.5 | July 2020)
TotalSuspiciousAmountText
29. Amount involved in this
report
31. Cumulative amount
122
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Code
B41
B42*
B43*
B44*
B45
B46
B47
B48*
B49*
B50
B51
Error Text
The element is recorded with a value
but the subtype of suspicious activity
is not equal to Other.
The value recorded for the element is
not in the required format (see Value
Restrictions for format requirements).
The value recorded for the element is
not in the required format
(YYYYMMDD).
The value recorded for the element is
not in the required format
(HH:MM:SS).
The element is not recorded or does
not contain.
The value recorded is not valid based
on the type of cyber event (see Value
Restrictions for format requirements).
The element is recorded for a cyberevent type that is not applicable to
this data (see Element Restrictions for
more information).
The value recorded for the element is
not in the required format
(YYYYMMDD).
The element is recorded for a cyberevent type that is not applicable to
this data (see Element Restrictions for
more information).
The value recorded for the element is
not in the required format
(HH:MM:SS).
The element is not recorded or does
not contain a value.
Severity
Associated Element(s)
Warning
IPAddressText
32z-42z. Suspicious
Activity: Other Type
Description
43. IP Address: Address
Warning
ActivityIPAddressDateText
43a. IP Address: Date
Warning
ActivityIPAddressTimeStampT
ext
43b. IP Address:
Timestamp
Warning
EventValueText
Warning
EventValueText
44a1-j1,z1. Cyber Event
Indicator: Event value
44a1-j1,z2. Cyber Event
Indicator: Event value
Fatal
CyberEventDateText
44a2,h2. Cyber Event
Indicator: Date
Warning
CyberEventDateText
44a2,h3. Cyber Event
Indicator: Date
Fatal
CyberEventTimeStampText
44a3,h3. Cyber Event
Indicator: Timestamp
Warning
CyberEventTimeStampText
44a3,h4. Cyber Event
Indicator: Timestamp
Fatal
CyberEventIndicatorsTypeCod
e
44a-j,z. Cyber Event
Indicator: Type (Command
and Control IP address,
Targeted system, etc.)
44a-j,z. Cyber Event
Indicator: Type (Command
and Control IP address,
Targeted system, etc.)
44z. Cyber Event Indicator:
Other Description
Warning
OtherSuspiciousActivityTypeT
ext
Form Reference
B52
The element contains an invalid code.
Fatal
CyberEventIndicatorsTypeCod
e
B53
The element is not recorded or does
not contain a value and the
is
equal to “11” Other.
The element is recorded with a value
and the
is
not equal to “11” Other.
The element is not recorded.
Warning
CyberEventTypeOtherText
Warning
CyberEventTypeOtherText
44z. Cyber Event Indicator:
Other Description
Fatal
AssetTypeID
The element is recorded but without
a value (i.e. the value is null).
Fatal
AssetTypeID
45/46. Assets: Type
(45. Financial product)
(46. Financial
instrument/payment
mechanism)
45/46. Assets: Type
(45. Financial product)
(46. Financial
instrument/payment
mechanism)
B54
B55
B56
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Code
Error Text
Severity
Associated Element(s)
B58
The element is not recorded.
Fatal
AssetSubtypeID
B59
The element is recorded but without
a value (i.e. the value is null).
Fatal
AssetSubtypeID
B60
The element contains an invalid code.
Fatal
AssetSubtypeID
B61
The element contains a value that is
not appropriate for the type of asset
recorded.
Fatal
AssetSubtypeID
B62
The element is not recorded or does
not contain a value and Other is
indicated for the
element.
The element is recorded with a value
and Other is not indicated for the
element.
The element is not recorded or does
not contain a value.
The value recorded is not valid based
on the type of asset attribute (see
Value Restrictions for format
requirements).
The element is not recorded.
Warning
OtherAssetSubtypeText
Warning
OtherAssetSubtypeText
45z/46z. Assets: Subtype
Other Description
Warning
AssetAttributeDescriptionText
Warning
AssetAttributeDescriptionText
47-50. Assets Attribute:
Value/Description
47-50. Assets Attribute:
Value/Description
Fatal
AssetAttributeTypeID
B67
The element is recorded but without
a value (i.e. the value is null).
Fatal
AssetAttributeTypeID
B68
The element contains an invalid code.
Fatal
AssetAttributeTypeID
B69
The element is not recorded.
Fatal
FilingDateText
B57
B63
B64
B65
B66
The element contains an invalid code.
Fatal
FinCEN SAR XML Schema User Guide (version 1.5 | July 2020)
AssetTypeID
Form Reference
45/46. Assets: Type
(45. Financial product)
(46. Financial
instrument/payment
mechanism)
45a-t,z/46a-i,z. Assets:
Subtype
(45. Bonds/Notes,
Microcap securities, etc.)
(46. Bank/cashier's check,
Funds transfer, etc.)
45a-t,z/46a-i,z. Assets:
Subtype
(45. Bonds/Notes,
Microcap securities, etc.)
(46. Bank/cashier's check,
Funds transfer, etc.)
45a-t,z/46a-i,z. Assets:
Subtype
(45. Bonds/Notes,
Microcap securities, etc.)
(46. Bank/cashier's check,
Funds transfer, etc.)
45a-t,z/46a-i,z. Assets:
Subtype
(45. Bonds/Notes,
Microcap securities, etc.)
(46. Bank/cashier's check,
Funds transfer, etc.)
45z/46z. Assets: Subtype
Other Description
47-50. Assets Attribute:
Type (Commodity,
Product/Instrument,
Market where traded, or
CUSIP)
47-50. Assets Attribute:
Type (Commodity,
Product/Instrument,
Market where traded, or
CUSIP)
47-50. Assets Attribute:
Type (Commodity,
Product/Instrument,
Market where traded, or
CUSIP)
95. Date filed
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Code
B70
B71
B72
Error Text
The element is recorded but without
a value (i.e. the value is null).
The value recorded for the element is
a date greater than the current date
or less than January 1, 2000.
The value recorded for the element is
not a valid date in the format
YYYYMMDD.
Severity
Associated Element(s)
Form Reference
Fatal
FilingDateText
95. Date filed
Fatal
FilingDateText
95. Date filed
Fatal
FilingDateText
95. Date filed
7.3. Subject Information Errors
These errors can occur at the FinCEN SAR document level associated with the Part I Subject Information:
Code
Error Text
Severity
Associated Element(s)
Form Reference
C0
The party type associated with the
subject is not recorded.
The party type associated with the
subject exceeds the maximum
occurrence for the FinCEN SAR.
The element is not recorded for the
subject and
does not contain a “Y”
value.
The element is not recorded or does
not contain a value for the subject
and unknown is not indicated.
The element is not recorded or does
not contain a value for an individual
subject and unknown is not
indicated.
More than one gender is recorded
for the subject.
Fatal
Party
Subject Information
Fatal
Party
Subject Information
Warning
PartyName
4-7. Name
Warning
RawEntityIndividualLastName
4. Name: Entity/Last
Warning
RawIndividualFirstName
5. Name: First
Warning
FemaleGenderIndicator
MaleGenderIndicator
UnknownGenderIndicator
08a-c. Gender
C53
A gender indicator element is
recorded with a “Y” value for the
entity subject.
Warning
08a-c. Gender
03a. Check if entity
C7
The element is not recorded for the
subject and
does not contain a “Y”
value.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element contains an invalid state
code.
The element is not recorded or does
not contains a value when the
country is US, CA, or MX, and
unknown is not indicated.
Warning
FemaleGenderIndicator
MaleGenderIndicator
UnknownGenderIndicator
PartyAsEntityOrganizationIndi
cator
Address
Warning
RawStreetAddress1Text
11. Address: Street
Warning
RawCityText
12. Address: City
Fatal
RawStateCodeText
13. Address: State
Warning
RawStateCodeText
13. Address: State
C1
C2*
C3*
C4
C6
C8
C9
C10
C11
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Code
C12
C13
C14
C15
C16
C17
C18
C19*
C20
C21*
C54
C22
C23
C24
C25
C26
C27
C28
C29
Error Text
The element contains a value and the
country is not US, CA, MX, or a U.S.
Territory.
State code and country code
mismatch when a U.S. Territory is
recorded.
The value recorded contains
punctuation or formatting.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The value recorded is not equal to 5
or 9 numeric characters, is a 9-digit
value ending in four zeros or four
nines, and the corresponding country
is equal to US or a U.S. Territory code.
The element contains an invalid
country code.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element is not recorded for the
subject TIN and
does not contain a “Y”
value.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The value recorded for the EIN or
SSN/ITIN is an invalid number string.
The element is not recorded or does
not contain a valid value.
The element is not recorded or does
not contain a value for the subject
Form of Identification and
does not contain a “Y”
value.
The element contains a value and
unknown is indicated.
The value recorded for the form of
identification number is an invalid
number string.
The element is not recorded or does
not contain a value, the form of
identification is Driver’s license/State
ID, and the country code is US, CA,
MX, or a U.S. Territory.
The element contains a value and
identification unknown is indicated.
The element contains an invalid state
code.
State code and country code
mismatch when U.S. Territory is
recorded.
The element is not recorded or does
not contain a value and the form of
Severity
Associated Element(s)
Form Reference
Warning
RawCountryCodeText
RawStateCodeText
13, 15. Address: State,
Country
Fatal
RawZIPCode
Warning
RawZIPCode
14. Address: ZIP/Postal
Code
14. Address: ZIP/Postal
Code
Warning
RawZIPCode
14. Address: ZIP/Postal
Code
Fatal
RawCountryCodeText
15. Address: Country
Warning
RawCountryCodeText
15. Address: Country
Warning
PartyIdentification
16-17. TIN
Fatal
PartyIdentificationNumberTex
t
16. TIN: Number
Warning
16. TIN: Number
Fatal
PartyIdentificationNumberTex
t
PartyIdentificationTypeCode
Warning
PartyIdentification
18. Form of ID
Warning
PartyIdentificationNumberTex
t
PartyIdentificationNumberTex
t
18e. Form of ID: Number
Warning
OtherIssuerStateText
18f. Form of ID: Issuing
State
Warning
OtherIssuerStateText
Warning
OtherIssuerStateText
Warning
OtherIssuerCountryText
OtherIssuerStateText
18f. Form of ID: Issuing
State
18f. Form of ID: Issuing
State
18f,g. Form of ID: Issuing
State/Country
Warning
OtherIssuerCountryText
Warning
Warning
FinCEN SAR XML Schema User Guide (version 1.5 | July 2020)
RawStateCodeText
13. Address: State
17. TIN: Type
18e. Form of ID: Number
18g. Form of ID: Issuing
Country
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Code
Error Text
Severity
Associated Element(s)
Form Reference
C30
The element contains a value and
identification unknown is indicated.
The element contains an invalid
country code.
The element is not recorded or does
not contain a value and the form of
identification is Other.
The element contains a value and
identification unknown is indicated.
The value recorded for the element is
not in the required format
(YYYYMMDD).
The element is not recorded for the
individual subject and
and
do
not contain a “Y” value.
The date of birth recorded is less
than January 1, 1900.
The element contains an invalid code.
Warning
OtherIssuerCountryText
Warning
OtherIssuerCountryText
Warning
OtherPartyIdentificationTypeT
ext
18g. Form of ID: Issuing
Country
18g. Form of ID: Issuing
Country
18z. Form of ID: Type Other Description
Warning
Warning
OtherPartyIdentificationTypeT
ext
IndividualBirthDateText
18z. Form of ID: Type Other Description
19. Date of birth: Date
Warning
IndividualBirthDateText
19. Date of birth: Date
Warning
IndividualBirthDateText
19. Date of birth: Date
Fatal
PhoneNumberTypeCode
The value recorded for the element is
not a valid email address or URL
format.
The element is not recorded or does
not contain a value (i.e. the value is
null).
The element contains an invalid code.
Warning
ElectronicAddressText
20a-d. Phone: Type (a.
Home, b. Work, c. Mobile,
d. Fax)
22,22a. E-Address: Address
Fatal
ElectronicAddressTypeCode
22,22a. E-Address: Type
Indicator
Fatal
ElectronicAddressTypeCode
The element is not recorded or at
least one indicator identifying the
type of relationship is not recorded
with a "Y" value.
The value recorded does not match
the TIN for the filing institution or a
financial institution where the activity
occurred.
The element is not recorded or does
not contain a value and Other is
indicated.
The element is recorded with a value
and Other is not indicated.
Warning
PartyAssociation
22,22a. E-Address: Type
Indicator
24. Subject Relationship to
FI (relationship type
indicators)
Fatal
SubjectRelationshipFinancialI
nstitutionTINText
24a. Subject Relationship
to FI: Institution TIN
Warning
OtherPartyAssociationTypeTe
xt
24z. Subject Relationship
to FI: Other description
Warning
OtherPartyAssociationTypeTe
xt
24z. Subject Relationship
to FI: Other description
The element is not recorded or does
not contain a value and the status of
the relationship is Terminated,
Suspended/barred, or Resigned.
The value recorded for the element is
not in the required format
(YYYYMMDD).
The element is recorded with a valid
value but the status of the
relationship is not equal to
Terminated, Suspended/barred, or
Resigned.
Warning
ActionTakenDateText
26. Subject Relationship to
FI: Action date
Warning
ActionTakenDateText
26. Subject Relationship to
FI: Action date
Warning
ActionTakenDateText
26. Subject Relationship to
FI: Action date
C31
C32
C33
C34
C35
C36
C37
C38
C39
C40
C41*
C42
C43
C44
C45
C46
C55
identification is Passport or Alien
registration.
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Code
C56
C57
C47
C48
C49
Error Text
The element is recorded with a valid
value but the type of relationship is
not equal to Director, Employee,
Officer, or Owner/Controlling
Shareholder.
The element is not recorded or does
not contain a value and the type of
relationship is equal to Director,
Employee, Officer, and/or
Owner/Controlling Shareholder.
The
NoKnownAccountInvolvedIndicator
element is recorded with a “Y” value
but the PartyAccountAssociation
element is also recorded.
The
NoKnownAccountInvolvedIndicator
element is not recorded and the
PartyAccountAssociation element is
also not recorded.
The element is not recorded or does
not contain a value.
Severity
Associated Element(s)
Form Reference
Warning
RelationshipContinuesIndicat
or; ResignedIndicator;
SuspendedBarredIndicator;
TerminatedIndicator
25. Subject Relationship to
FI: Status of relationship
Warning
NoKnownAccountInvolvedInd
icator
PartyAccountAssociation
Account
27. Related FI
TIN/Account(s)/No known
accounts involved
Warning
NoKnownAccountInvolvedInd
icator
PartyAccountAssociation
Account
27. Related FI
TIN/Account(s)/No known
accounts involved
Fatal
PartyAccountAssociationType
Code
27. Account: Party
Association Type (Subject
Identifier)
27. Account: Party
Association Type (Subject
Identifier)
28a-c. Subject role in
transaction
Warning
RelationshipContinuesIndicat
or; ResignedIndicator;
SuspendedBarredIndicator;
TerminatedIndicator
C50
The element contains an invalid code.
Fatal
PartyAccountAssociationType
Code
C51
More than one role is recorded for
the subject.
Warning
C52*
Subject relationship to institution is
categorized as Director, Employee,
Officer, and/or Owner/Controlling
Shareholder, and Joint report is
indicated.
Warning
BothPurchaserSenderPayeeRe
ceiveIndicator
PayeeReceiverIndicator
PurchaserSenderIndicator
ActivityAssociation
(DirectorIndicator,
EmployeeIndicator,
OfficerIndicator,
OwnerShareholderIndicator);
PartyAssociation
(JointReportIndicator)
25. Subject Relationship to
FI: Status of relationship
24h/i/k/l. Subject
relationship to institution;
1d. Joint report
7.4. Financial Institution & Branch Where Activity Occurred Errors
These errors can occur at the FinCEN SAR document level associated with the Part III Financial Institution Where
Activity Occurred Information, as well as the Branch location (if any):
Code
Error Text
Severity
Associated Element(s)
Form Reference
D0
The party type associated with the
financial institution where activity
occurred is not recorded.
The party type associated with the
financial institution where activity
occurred exceeds the maximum
occurrence for the FinCEN SAR.
The element is not recorded.
Fatal
Party
FI Where Activity Occurred
Fatal
Party
FI Where Activity Occurred
Fatal
OrganizationClassificationTyp
eSubtype
51, 53-54. Institution
Type/Subtype
The element is not recorded or does
not contain a value (i.e. the value is
null).
Fatal
OrganizationTypeID
51a-g,z. Institution Type
D1
D2
D3
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Code
Error Text
Severity
Associated Element(s)
Form Reference
D5
The element is not recorded or does
not contain a value and the
institution type is equal to Other.
The element is recorded with a value
but the institution type is not equal
to Other.
The element is not recorded.
Warning
OtherOrganizationTypeText
51z. Institution Type Other
Description
Warning
OtherOrganizationTypeText
51z. Institution Type Other
Description
Fatal
PrimaryRegulatorTypeCode
52a-i. Primary Federal
Regulator
D8
The element is recorded but with no
value (i.e. the value is null).
Fatal
PrimaryRegulatorTypeCode
52a-i. Primary Federal
Regulator
D9
The element contains an invalid code.
Fatal
PrimaryRegulatorTypeCode
52a-i. Primary Federal
Regulator
D10
The element is not recorded or does
not contain a value (i.e. the value is
null) and the institution type is equal
to Casino/Card club or Securities and
Futures.
Fatal
OrganizationSubtypeID
D11
The element contains an invalid code.
Fatal
OrganizationSubtypeID
D12
The element contains a value but the
institution type is not equal to
Casino/Card club or Securities and
Futures.
Fatal
OrganizationSubtypeID
D14
The value recorded conflicts with the
institution type recorded (e.g. State
Casino recorded for Securities and
Futures institution)
Fatal
OrganizationSubtypeID
D15
The element is not recorded or does
not contain a value and the
institution subtype is equal to Other.
Warning
OtherOrganizationSubTypeTe
xt
D16
The element is recorded with a value
but the institution subtype is not
equal to Other.
Warning
OtherOrganizationSubTypeTe
xt
53a-c,z
54a-k,z. Institution
Subtype: Gaming
Institution,
Institution Subtype:
Securities/Futures
Institution
53a-c,z
54a-k,z. Institution
Subtype: Gaming
Institution,
Institution Subtype:
Securities/Futures
Institution
53a-c,z
54a-k,z. Institution
Subtype: Gaming
Institution,
Institution Subtype:
Securities/Futures
Institution
53a-c,z
54a-k,z. Institution
Subtype: Gaming
Institution,
Institution Subtype:
Securities/Futures
Institution
53z
54z. Institution Subtype
Other: Gaming Institution
Description
Institution Subtype Other:
Securities/Futures
Institution Description
53z
54z. Institution Subtype
Other: Gaming Institution
Description
Institution Subtype Other:
Securities/Futures
Institution Description
D4
D6
D7
The element contains an invalid code.
Fatal
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OrganizationTypeID
51a-g,z. Institution Type
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Code
D17
D51
Error Text
The element is not recorded or does
not contain a value and unknown is
not indicated.
More than one role is recorded for
the financial institution’s role in
transaction.
Severity
Associated Element(s)
Form Reference
Warning
56a-b. Role in transaction
Fatal
PartyIdentificationNumberTex
t
55h. Institution ID: Number
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element is recorded with a value
for the legal name and unknown is
indicated.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The value recorded for the EIN or
SSN/ITIN is an invalid number string.
Fatal
PayLocationIndicator
SellingLocationIndicator
SellingPayingLocationIndicato
r
RawPartyFullName
Warning
RawPartyFullName
57. Name: Legal name of FI
Fatal
PartyIdentificationNumberTex
t
59. TIN: Number
Warning
PartyIdentificationNumberTex
t
59. TIN: Number
D52
The element is not recorded or does
not contain a valid value.
Fatal
PartyIdentificationTypeCode
60. TIN: Type
D22
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element contains an invalid state
code.
Warning
RawStreetAddress1Text
61. Address: Address/Street
Warning
RawCityText
62. Address: City
Fatal
RawStateCodeText
63. Address: State
The element is not recorded or does
not contain a value when the country
is US, CA, MX, or a U.S. Territory.
The element contains a value and the
country is not US, CA, MX, or a U.S.
Territory.
State code and country code
mismatch when U.S. Territory is
recorded.
The value recorded contains
punctuation or formatting.
Warning
RawStateCodeText
63. Address: State
Warning
RawStateCodeText
63. Address: State
Warning
RawCountryCodeText
RawStateCodeText
63, 65. Address: State,
Country
Fatal
RawZIPCode
64. Address: ZIP/Postal
Code
The element is not recorded or does
not contain a value and unknown is
not indicated.
The value recorded is not equal to 5
or 9 numeric characters, is a 9-digit
value ending in four zeros or four
nines, and the corresponding country
is equal to US or a U.S. Territory code.
The element contains an invalid
country code.
Warning
RawZIPCode
64. Address: ZIP/Postal
Code
Warning
RawZIPCode
64. Address: ZIP/Postal
Code
Fatal
RawCountryCodeText
65. Address: Country
The element is not recorded or does
not contain a value and unknown is
not indicated.
The loss to financial institution
amount recorded contains one or
more non-numeric characters.
Warning
RawCountryCodeText
65. Address: Country
Warning
LossToFinancialAmountText
67. Loss to financial
institution (amount)
D18
D19
D20
D21*
D23
D24
D25
D26
D27
D28
D29
D30
D31
D32
D33
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130
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Code
Error Text
Severity
Associated Element(s)
Form Reference
D34
The loss to financial institution
amount recorded is greater than the
amount recorded for
The element is recorded but no
relationship indicator is recorded
with a “Y” value.
This element is recorded with a “Y”
value for the Financial institution (34)
but one or more Branch (46) party
type locations are also recorded.
The party type associated with the
branch where activity occurred is not
recorded and "no branch activity
involved" is not indicated.
The party type associated with the
branch where activity occurred
exceeds the maximum occurrence for
the FinCEN SAR.
More than one role is recorded for
the branch’s role in the transaction.
Warning
LossToFinancialAmountText
67. Loss to financial
institution (amount)
Warning
PartyAssociation
67. FI/Branch Party
Association
Warning
NoBranchActivityInvolvedIndi
cator
69a. No branch activity
involved indicator
Warning
Party
Branch Location
Fatal
Party
Branch Location
Warning
PayLocationIndicator
SellingLocationIndicator
SellingPayingLocationIndicato
r
68a-c. Role in transaction
D41
The element is not recorded for the
Branch and
does not contain a "Y" value.
Warning
Address
69, 71-74. Address
D44
The element contains an invalid state
code.
The element contains a value and the
country is not US, CA, MX, or a U.S.
Territory.
The element is not recorded or does
not contain a value when the country
is a U.S. Territory.
State code and country code
mismatch when U.S. Territory is
recorded.
Fatal
RawStateCodeText
72. Address: State
Warning
RawStateCodeText
72. Address: State
Warning
RawStateCodeText
72. Address: State
Warning
RawCountryCodeText
RawStateCodeText
72, 74. Address: State,
Country
The element contains an invalid
country code.
The element is not recorded or does
not contain a value.
Fatal
RawCountryCodeText
74. Address: Country
Warning
RawCountryCodeText
74. Address: Country
D53
D35
D36
D37
D38
D39
D45
D46
D47
D49
D50
The loss to financial institution
amount recorded is equal to zero.
Warning
LossToFinancialAmountText
67. Loss to financial
institution (amount)
7.5. Filing Institution Errors
These errors can occur at the FinCEN SAR document level associated with the Part IV Filing Institution Information:
Code
Error Text
Severity
Associated Element(s)
Form Reference
E0
The party type associated with the
filing institution is not recorded.
Fatal
Party
Filing Institution
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Code
Severity
Associated Element(s)
Form Reference
Fatal
PrimaryRegulatorTypeCode
Fatal
PrimaryRegulatorTypeCode
E4
The element is recorded but with no
value (i.e. the value is null).
The element contains an invalid code.
Fatal
PrimaryRegulatorTypeCode
E5*
The element is not recorded.
Warning
RawPartyFullName
75a-i, z. Primary Federal
Regulator
75a-i, z. Primary Federal
Regulator
75a-i, z. Primary Federal
Regulator
76. Name: Legal name
Fatal
PartyIdentificationNumberTex
t
77. TIN: Number
Warning
PartyIdentificationNumberTex
t
PartyIdentificationTypeCode
77. TIN: Number
Fatal
OrganizationClassificationTyp
eSubtype
OrganizationTypeID
79, 80. Institution
Type/Subtype
79a-g,z. Institution Type
Fatal
OrganizationTypeID
79a-g,z. Institution Type
Warning
OtherOrganizationTypeText
79z. Institution Type Other
Description
Fatal
OrganizationSubtypeID
80a-n,z. Institution
Subtype: Securities/Futures
Institution
Fatal
OrganizationSubtypeID
Fatal
OrganizationSubtypeID
Fatal
OrganizationSubtypeID
80a-n,z. Institution
Subtype: Securities/Futures
Institution
80a-n,z. Institution
Subtype: Securities/Futures
Institution
80a-n,z. Institution
Subtype: Securities/Futures
Institution
Warning
OtherOrganizationSubTypeTe
xt
Warning
OtherOrganizationSubTypeTe
xt
Fatal
PartyIdentificationNumberTex
t
Warning
PartyIdentificationNumberTex
t
E1
E2
E3
E6*
E7
E9*
E46
E10
E11
E12
E13
E14
E15
E16
E17
E19
E20
E47
E21
E22
Error Text
The party type associated with the
filing institution exceeds the
maximum occurrence for the FinCEN
SAR.
The element is not recorded.
The element is recorded but with no
value (i.e. the value is null).
The element is not recorded or does
not contain a value for the filing
institution TIN.
The value recorded for the EIN or
SSN/ITIN is an invalid number string.
The element is not recorded or does
not contain a valid value.
The element is not recorded.
The element is not recorded or does
not contain a value (i.e. the value is
null).
The element contains an invalid code.
The element is not recorded or does
not contain a value and the
institution type is equal to Other.
The element is recorded with a value
but the institution type is not equal
to Other.
The element is not recorded or does
not contain a value (i.e. the value is
null) and the institution type is equal
to Securities and Futures.
The element contains an invalid code.
The element contains a value but the
institution type is not equal to
Securities and Futures.
The value recorded conflicts with the
institution type recorded (e.g. State
Casino recorded for Securities and
Futures institution)
The element is recorded with a value
but the institution subtype is not
equal to Other.
The element is not recorded or does
not contain a value and the
institution subtype is equal to Other.
The element is not recorded or does
not contain a value for the filing
institution identification number.
The value recorded for the
identification number is an invalid
number string.
Fatal
Warning
Fatal
Fatal
Warning
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Party
RawPartyFullName
OtherOrganizationTypeText
Filing Institution
76. Name: Legal name
78. TIN: Type
79z. Institution Type Other
Description
80z. Institution Subtype
Other: Securities/Futures
Institution Description
80z. Institution Subtype
Other: Securities/Futures
Institution Description
81h. Institution ID: Number
81h. Institution ID: Number
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Code
E24
E26
E27
E28
E30
E31
E32
E34
E35
E36
E37
E39
E40
E41
E42
E43
E44
E45
Error Text
The element is not recorded or does
not contain a value for the filing
institution.
The element is not recorded or does
not contain a value for the filing
institution.
The element contains an invalid state
code.
The element is not recorded or does
not contain a value for the filing
institution when the country is US,
CA, MX, or a U.S. Territory.
The element contains a value and the
country is not US, CA, MX, or a U.S.
Territory.
State code and country code
mismatch when U.S. Territory is
recorded.
The value recorded contains
punctuation or formatting.
The element is not recorded or does
not contain a value for the filing
institution.
The value recorded is not equal to 5
or 9 numeric characters, is a 9-digit
value ending in four zeros or four
nines, and the corresponding country
is equal to US or a U.S. Territory code.
The element contains an invalid
country code.
The element is not recorded or does
not contain a value for the filing
institution.
The party type associated with the
designated contact office is not
recorded.
The party type associated with the
designated contact office exceeds the
maximum occurrence for the FinCEN
SAR.
The element is not recorded or does
not contain a value for the
Designated contact office.
The element is not recorded or does
not contain a value for the
designated contact office.
The party type associated with the LE
contact agency exceeds the
maximum occurrence for the FinCEN
SAR.
The party type associated with the LE
contact name exceeds the maximum
occurrence for the FinCEN SAR.
The value recorded for the element is
not in the required format
(YYYYMMDD).
Severity
Associated Element(s)
Form Reference
Warning
RawCityText
83. Address: City
Fatal
RawStateCodeText
84. Address: State
Warning
RawStateCodeText
84. Address: State
Warning
RawStateCodeText
84. Address: State
Warning
RawCountryCodeText
RawStateCodeText
8486. Address
Fatal
RawZIPCode
Warning
RawZIPCode
85. Address: ZIP/Postal
Code
85. Address: ZIP/Postal
Code
Warning
RawZIPCode
85. Address: ZIP/Postal
Code
Fatal
RawCountryCodeText
86. Address: Country
Warning
RawCountryCodeText
86. Address: Country
Fatal
Party
93. Designated Contact
Office
Fatal
Party
93. Designated Contact
Office
Fatal
RawPartyFullName
93. Name: Legal name
Warning
PhoneNumberText
94. Phone: Number
Fatal
Party
89. LE Contact Agency
Fatal
Party
90. LE Contact Name
Fatal
ContactDateText
92. LE contact date
Warning
RawStreetAddress1Text
82. Address: Address/Street
7.6. Attachment & Narrative Errors
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These errors can occur at the FinCEN SAR document level associated with the Part V Attachment & Narrative
Information:
Code
Error Text
Severity
Associated Element(s)
Form Reference
F0
The batch submission contains an
attachment but the
element is not recorded or does not
contain a value.
The element is recorded with a valid
value but there is no corresponding
attachment.
The element is not recorded.
Fatal
OriginalAttachmentFileName
FinCEN SAR Attachment
Fatal
OriginalAttachmentFileName
FinCEN SAR Attachment
Fatal
ActivityNarrativeInformation
Narrative
F1
F2
F3
The element is not recorded or does
not contain a value.
The element contains an invalid code.
F4
F5
The element is not recorded or does
not contain a value.
Fatal
Fatal
Fatal
ActivityNarrativeSequenceNu
mber
ActivityNarrativeSequenceNu
mber
ActivityNarrativeText
Narrative: Sequence
Number
Narrative: Sequence
Number
Narrative:
Value/Description
7.7. Transmitter Errors
These errors can occur at the FinCEN SAR document level associated with Transmitter of the batch:
Code
Error Text
Severity
Associated Element(s)
Form Reference
G0
A required party associated with the
transmitter is missing.
The report contains more than one
party associated with the transmitter.
The element is not recorded or does
not contain a value
The element is not recorded or does
not contain a value
The element is not recorded or does
not contain a value
The element is not recorded or does
not contain a value and unknown is
not indicated.
The element contains a value that is
not a valid code
The element is not recorded or does
not contain a value
The value recorded contains one or
more non-numeric characters or is in
an invalid format and the country is
US
The element is not recorded or does
not contain a value
The element contains a value that is
not a valid code
State code and country code
mismatch when U.S. Territory is
recorded
The element contains an invalid
number string for a US TIN
Fatal
Party
NA
Fatal
Party
NA
Warning
Transmitter Name
NA
Warning
Transmitter Address
NA
Warning
Transmitter City
NA
Warning
Transmitter State
NA
Warning
Transmitter State
NA
Warning
Transmitter ZIP/Postal Code
NA
Warning
Transmitter ZIP/Postal Code
NA
Warning
Transmitter Country
NA
Warning
Transmitter Country
NA
Warning
Transmitter Country
NA
Warning
Transmitter Taxpayer
Identification Number (TIN)
NA
The element is not recorded or does
not contain a value
Warning
Transmitter Taxpayer
Identification Number (TIN)
NA
G1
G2
G3
G4
G5
G6
G7
G8
G9
G10
G11
G12
G13
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Code
Error Text
Severity
G15
The element contains a value that is
not a valid code
Fatal
G16
The Transmitter Control Code (TCC)
specified in the file is not a valid TCC.
For production, the TCC must begin
with “P” and for User Test, it must be
equal to “TBSATEST”.
Fatal
G19
The value recorded for the element
contains non-numeric characters
The element is not recorded or does
not contain a value (i.e. the value is
null).
Warning
G14
G20
The element is recorded but without
a value (i.e. the value is null).
Fatal
Warning
Associated Element(s)
Transmitter Taxpayer
Identification Number (TIN)
or Control Code (TCC) Type
Transmitter Taxpayer
Identification Number (TIN)
or Control Coe (TCC) Type
Transmitter Control Code
(TCC) Number
Transmitter Telephone
Number
Transmitter Telephone
Number
Form Reference
NA
NA
NA
NA
NA
7.8. Transmitter Contact Errors
These errors can occur at the FinCEN SAR document level associated with contact person for the Transmitter of the
batch:
Code
Error Text
Severity
Associated Element(s)
Form Reference
H0
A required party associated with the
transmitter contact is missing.
The report contains more than one
party associated with the transmitter
contact.
The element is not recorded or does
not contain a value
Fatal
Party
NA
Fatal
Party
NA
Warning
Transmitter Contact Name
NA
H1
H2
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8. 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 main categories of errors identified in batch files: Schema validation errors that result in automatic
rejection of the batch file and data errors that represent errors in data entered for individual elements but may not
result in a rejection.
Schema validation errors prevent the batch file from being processed and are considered fatal errors. An example of a
schema validation error is a missing required element or an element sequence that does not match the schema. An
example of a data error is a required element that contains no value. Data errors are classified as primary or
secondary warnings, depending on their importance. Primary warnings are file errors that violate electronic filing
requirements or instructions and so degrade FinCEN SAR data quality that they must be corrected. Primary warnings
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 warnings 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 Descriptions identifies primary errors by adding an asterisk (*) to
the error code.
Secondary warnings are data 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.
When an accepted batch file contains FinCEN SARs with primary warning errors, those FinCEN SARs 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 data 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:
Financial Crimes Enforcement Network
Office of Domestic Liaison
Data Quality Assessments
P.O. Box 39
Vienna, VA 22183
This correspondence should explain the technical issues involved that prevent meeting the time frame, provide an
estimate of when the issues will be resolved, and include a contact name and telephone number.
Correction Procedures:
FinCEN SAR batch files are rejected when they contain fatal format errors. Filers must correct all fatal errors identified
in the batch file and resubmit the batch file to BSA E-Filing. Because they were not accepted by FinCEN, initial report
FinCEN SARs in the re-submitted batch file are still initial reports. Do not identify FinCEN SARs from a rejected batch
file as Amended reports unless they originally were filed as Amended reports.
If errors involve accepted with warning errors in the FinCEN SARs of an accepted batch file, filers should correct all
errors and file amended reports on the affected FinCEN SARs using the following procedures:
•
Make the corrections to all errors in the FinCEN SARs in the accepted batch file.
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•
•
•
•
•
Record “Y” in the element under the element
in each FinCEN SAR to be corrected.
Record in the element under the element the BSA Identifier
(from the FinCEN SAR Acknowledgement) that was assigned to the FinCEN SAR being corrected.
Ensure that the element contains a new date.
Complete all other data in the FinCEN SAR in their entirety.
Retransmit the corrected FinCEN SAR 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.
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9. Attachment C – Electronic XML 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.”
9.1. Confidentiality of FinCEN SARs:
A FinCEN Suspicious Activity Report (FinCEN SAR), and any information that would reveal the existence of the FinCEN
SAR (collectively, “FinCEN SAR information”), is 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).
9.2. FinCEN SAR Sharing:
FinCEN, the Federal Banking Regulators, the Securities and Exchange Commission (SEC), and the Commodity Futures
Trading Commission (CFTC) have concluded that any depository institution, broker-dealer in securities, futures
commission merchant, and introducing broker in commodities may share the FinCEN SAR, or any information that
would reveal the existence of the FinCEN SAR, with its head office or parent entity (whether domestic or foreign). (See
“Interagency Guidance on Sharing Suspicious Activity Reports with Head Offices and Controlling Companies,” January
20, 2006 and “Guidance on Sharing of Suspicious Activity Reports by Securities Broker-Dealers, Futures Commission
Merchants, and Introducing Brokers in Commodities,” January 20, 2006.)
In addition, any depository institution, broker-dealer in securities, futures commission merchant, introducing broker in
commodities, or casino that has filed a FinCEN SAR may share the FinCEN SAR, or any information that would reveal
the existence of the FinCEN SAR, with an affiliate, as defined in FinCEN guidance (respectively, FIN-2010-G006
“Sharing Suspicious Activity Reports by Depository Institutions with Certain U.S. Affiliates,” Nov. 23, 2010; FIN-2010G005, “Sharing Suspicious Activity Reports by Securities Broker-Dealers, Mutual Funds, Futures Commission
Merchants, and Introducing Brokers in Commodities with Certain U.S. Affiliates;” FIN-2017-G001, “Sharing Suspicious
Activity Reports with U.S. Parents and Affiliates of Casinos,” January 4, 2017), provided the affiliate is subject to a
FinCEN SAR regulation. The sharing of FinCEN SARs with head offices and affiliates facilitates the identification of
suspicious transactions taking place through the depository institution’s affiliates that are subject to a FinCEN SAR
rule. Therefore, such sharing within the depository institution’s corporate organizational structure is consistent with the
purposes of Title II of the BSA.
9.3. 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 FinCEN SAR information to certain governmental authorities or other examining authorities
that are otherwise entitled by law to receive FinCEN SAR information or to examine for or investigate
suspicious activity;
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 SEC,
and the CFTC), the sharing of FinCEN SAR information within an institution’s corporate organizational
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structure, for purposes that are consistent with the Bank Secrecy Act, as determined by regulation or
guidance.
9.4. 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 FinCEN SAR, or any information that would
reveal the existence of a FinCEN 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.
9.5. FinCEN SAR Filing Instructions:
1. Who Must File: Certain financial institutions 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); Residential
Mortgage Lenders and Originators (31 CFR § 1029.320), and Housing Government Sponsored Enterprises
(31 CFR § 1030.320).
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 transactions that may relate to terrorist activity may call FinCEN’s Financial Institutions Hotline at 1-866556-3974 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.
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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 institution- affiliated parties as having committed or
aided in the commission of a criminal act regardless of the amount involved in the violation.
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 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.
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•
•
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.
9.6. FinCEN SAR Electronic Filing Instructions
9.6.1. General Instructions:
1.
2.
Filing Reports: This report must 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 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 in XML format of
Bank Secrecy Act (BSA) Reports” (General Specifications) and “FinCEN Suspicious Activity Report (FinCEN
SAR) XML Filing Requirements.”
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 the
General Instructions the item’s instructions must be followed. These instructions supersede all prior FinCEN
SAR instructions and FinCEN guidance on use of special responses in FinCEN 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 phrases “check box” and “select option” or similar wording is used
to denote checking an appropriate box or selecting a drop-down list option in certain data items on the
discrete FinCEN SAR. These are deemed equivalent to instructions in the XML Filing Requirements to enter
appropriate codes or responses in the same data items in XML-format transmission files. For example, the
requirement to check box 1 “Initial report” in the discrete FinCEN SAR is the equivalent of entering “Y” in
XML element .
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
XML elements for that item in the XML 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 recording multiple XML elements and appropriate
sub-elements for the same subject.
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3.
4.
5.
6.
Corrected/Amended Reports: A corrected report on a previously-filed FinCEN SAR or prior FinCEN SAR
version 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 FinCEN 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 BSA Identifier (BSA ID) must be entered in field 1e. If
the prior report’s 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 FinCEN 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 FinCEN SAR version. FinCEN SAR items not on the prior FinCEN SAR version need not be described
in the narrative. BSA IDs are provided in acknowledgement records sent to member financial institutions by
the BSA E-Filing System.
Continuing Reports: A continuing report may be filed on suspicious activity that continues after an initial
FinCEN SAR is filed. Continuing reports should be filed on successive 90-day review periods until the
suspicious activity ceases, but may be filed more frequently if circumstances warrant that. Filers have up to 30
days following the end of a review period to file the continuing report for a total of 120 days of review and
filing deadline. 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 29 and the cumulative dollar amount for the
current and prior related reports in Item 31. If continuing losses are involved for a financial institution
recorded in Part III, record the 90-day loss in Item 67 and the cumulative loss in Part V.
Joint Report: A FinCEN SAR may be jointly filed when two or more distinct financial institutions recorded in
Part III “Information about Financial Institution Where Activity Occurred” 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 24 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 51 through 65 and joint filer branch
information in Part III Items 68 through 74. 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 FinCEN 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.
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 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
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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 or
U.S. Territory 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 12345-6120 would be entered as
123456120. The foreign postal code HKW 702 would be entered HKW702. When an address is in a U.S.
Territory the territory code must be entered in the state and country fields. For other foreign addresses enter
the street address, city, postal code, and two letter country code or address equivalents. Leave the state item
blank, including the “Unknown box” when provided. If a foreign address contains address information that
does not conform to the FinCEN SAR address format, record equivalent address information in the FinCEN
SAR address items (except state) and ignore non-conforming data. The complete foreign address should be
recorded in the FinCEN SAR’s Part V narrative section. Complete any address item that is known, even if the
entire address is not known. 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. U.S. State codes must conform to the codes used by the United States Postal Service as
documented in ISO 3166-2:US. Canadian province and territory codes must conform to the codes used by
the Canadian Post Corporation as documented in ISO 3166-2:CA. Mexican state and federal district codes
must conform to ISO 3166-2:MX. Country codes and U.S. Territory Codes must conform to the codes
documented in ISO 3166-2. The ISO lists are available through the International Standards Organization.
NOTE: The ISO 3166-2 country list contains the code “UM” that stands for the United State Minor Outlying
Islands. Using “UM” in country fields is prohibited. These islands are uninhabited. As such they have no
addresses.
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 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 rounded up to $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. AKA
b. COMPUTER GENERATED
c. CUSTOMER
d. DBA
e. NON CUSTOMER
f. NONE
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g. NOT APPLICABLE
h. OTHER
i.
SAME
j.
SAME AS ABOVE
k. SEE ABOVE
l.
SEE NARRATIVE
m. SIGNATURE CARD
n. T/A
o. UNKNOWN
p. VARIOUS
q. 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 FinCEN 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 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. Entry of middle
initials is permitted when a middle name is unknown. Do not include a period after a middle initial when the
initial represents a name abbreviation. Abbreviations in names are prohibited unless an abbreviation is part
of a legal name or the 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.
13. Reporting Cyber Events: Cyber events directly affecting the financial institution or the financial institution’s
customer are occurring on an ever-increasing basis. Since the implementation of the new FinCEN SAR in 2011,
a significant number of FinCEN SARs have been filed to record the events with the data being recorded in Part
V, the FinCEN SAR Narrative. The data collected and submitted has provided law enforcement with valuable
leads and insight into this emerging field. A review of the data reported indicates that prompt retrieval of
cyber event information is a critical step in combating malicious cyber activity. To facilitate and support
prompt identification and retrieval of malicious cyber event information, specific cyber fields (42, 43, and 44)
have been added to Part II, the Suspicious Activity Information section of the FinCEN SAR. These fields are not
meant to be exhaustive or to replace attachments. Use of these fields to highlight selected information (that
may also be in attachments) can assist law enforcement in identifying key indicators. Due to the growing
prevalence and technological sophistication of cyber-enabled financial crime, FinCEN encourages financial
institutions to develop a basic understanding of what comprises a cyber event. Being familiar with selected
key vocabulary is essential in describing these cyber events to law enforcement. Completion of cyber event
fields 42 to 44 is not mandatory, but is encouraged where financial institutions have sufficient capacity to do
so. While use of the fields may not be mandatory, filing on certain cyber events and cyber-enabled financial
crime may be mandatory under existing filing requirements—see FinCEN Advisory FIN-2016-A005 for more
information.
A principal source of cyber related information will be the financial institutions’ internal technology
department or external technology contractor. FinCEN recognizes that institutions have varying familiarity
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with and access to cyber-related information in their compliance departments and therefore encourages the
involvement of available IT resources on an ongoing basis. Financial institutions should review established
internal departmental protocols to ensure prompt review and reporting of cyber event information.
Reporting cyber event information is not a new requirement and financial institutions are expected to report
this information when available. To assist institutions in identifying when to use the new cyber fields, FinCEN
is providing the examples below. Please note that these examples highlight instances where an institution
may be limited in its ability to identify cyber-related information due to limits in cyber expertise or resource
availability. Each example is an acceptable and appropriate use of these fields.
Example 1.
Bank A is told by its customer, ABC Corp, that a recent wire payment issued from its account was fraudulent.
Bank A is told that fraudsters imitated the CEO of ABC Corp.’s e-mail to instruct ABC employees to wire
funds from ABC’s accounts at Bank A to an account at Bank B. ABC Corp tells Bank A that these fraudulent emails were made to look like the CEO used the e-mail address [email protected] instead of the legitimate
[email protected]. These fraudulent e-mails appeared to be instructing employees to issue urgent
payments to one of ABC’s suppliers for $300,000. Bank A recognizes this as a Business E-mail Compromise
(BEC) scheme. In the FinCEN SAR narrative, Bank A describes the incident and mentions the term “BEC Fraud”
and FinCEN advisory FIN-2016-A003.
Bank A places the following information in the new fixed fields on the FinCEN SAR form:
Item 42: Cyber Event
b. Against Financial Institution Customer(s) [check box]
Field 44f. Suspicious e-mail address
44f1. Event value: [email protected]
Example 2.
Bank A is told by its customer, ABC Corp, that a recent wire payment issued from its account was fraudulent.
Bank A is told by its customer that the CEO of ABC Corp.’s e-mail was hacked and used to instruct ABC
employees to wire funds from ABC’s accounts at Bank A to an account at Bank B. ABC Corp tells Bank A that
these e-mails were made to look like the CEO was instructing employees to issue payments to ABC’s
suppliers for $300,000. No additional technical information was provided to Bank A. Bank A recognizes this
as a Business E-mail Compromise (BEC) scheme. In the FinCEN SAR narrative, Bank A describes the incident
and mentions the term “BEC Fraud” and FinCEN advisory FIN-2016-A003.
Bank A places the following information in the new fixed fields on the FinCEN SAR form:
Item 42: Cyber Event
b. Against Financial Institution Customer(s) [check box]
Item 44: BLANK
Example 3.
Bank C identifies a cyber incident that targeted Bank C’s own systems, resulting in access to Bank C’s
payment systems and an attempted transfer of $1 million through Bank C’s 123-wire system. Bank C’s
compliance team asks its IT department for additional technical information related to this incident, and
whether there were any key indicators associated with the event. The IT department is still gathering
information, but has identified one piece of relevant malware and the IP address that relayed instructions to
attempt the $1 million funds transfer. They also have a .csv file containing possibly related technical
information that Bank C decides to include as an attachment.
Bank C files a FinCEN SAR with the following information in the new fixed fields:
Item 42: Cyber Event
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a.
Against Financial Institution [check box]
Field 44a. Command & Control IP Address
44a1. Event value: 127.0.0.1
44a2. Date (2017/01/01)
44a3. UTC Time (00:00:01)
Field 44c. Malware MD5, Malware SHA-1, Malware SHA-256:
44c1Event value: 9e107d9d372bb6826bd81d3542a419d6
Field 44j. Targeted System:
44j1. Event value: 123-wire
Example 4.
Bank D identifies an incident that targeted Bank D’s own systems, resulting in access to Bank D’s payment
systems and an attempted transfer of $50,000 through Bank D’s 123-wire system. Bank D’s compliance team
asks its IT department for additional technical information related to this incident, and whether there were
any key indicators associated with the event. Bank D’s IT department confirms that the incident was a cyber
event against Bank D, but is unable to spend resources locating additional information due to their
necessary focus on continuity of business operations. Bank D files a FinCEN SAR based on the available
information.
Bank D files a FinCEN SAR with the following information in the fixed fields:
Item 42: Cyber Event
a. Against Financial Institution [check box]
Field 44j. Targeted System:
44j1. Event Indicator value: 123-wire
Example 5.
Bank E is told by its customer that a fraudulent wire was sent from their online banking account. The
customer does not know how fraudsters gained access to their account. Bank D is able to identify the record
of the fraudulent wire and when it occurred. Bank D’s compliance department asks its IT department for IP
log information associated with the targeted customer’s account at the time of the fraudulent wire transfer.
The IT department is able to provide the information from their logs.
Bank E files a FinCEN SAR with the following information in the new fixed fields:
Item 43:
a. IP address: 127.0.0.1
b. Date: 2017-01-30
c. UTC Time: 00:00:01
9.6.2. Item Instructions:
NOTE: Critical fields are identified with the * symbol in front of the data element number.
-------------------------------------------------- Type of Filing --------------------------------------------*1. Type of filing (check all that apply)
a.
b.
c.
d.
e.
Initial report
Correct/Amend prior report
Continuing activity report
Joint report
Prior report BSA Identification Number if items 1b or 1c are checked
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Item *1 Type of filing: Check box 1a "Initial report" if this is the first report filed on the suspicious activity. Check box
1b "Correct/Amend prior report" if the report corrects or amends a previously-filed FinCEN SAR. See General
Instruction 3 for additional instructions on filing corrected or amended SARs. Check box 1c "Continuing activity
report" if the FinCEN SAR continues reporting on previously-reported suspicious activity. If the FinCEN SAR corrects a
previously-filed continuing activity report, both 1b and 1c must be checked. See General Instruction 4 for additional
instructions on filing continuing activity reports. Check box 1d “Joint report” if a FinCEN SAR of any filing type is filed
jointly by two or more financial institutions. See General Instruction 5 for additional instructions on filing joint reports.
If box 1b or 1c is checked, the prior report’s BSA Identifier (BSA ID) must be recorded in field 1e. Enter 14 zeros if the
prior report BSA ID is unknown.
2. Filing Institution Note to FinCEN
Item 2, Filing Institution Note to FinCEN: This 50 character field is provided for
the filer to alert FinCEN that this FinCEN SAR is being filed in response to a current specific geographic targeting
order (GTO) or advisory or other activity. If completing for a GTO or advisory enter the GTO or advisory title/reference.
Provide a brief description of the other activity. Leave Item 2 blank if the FinCEN SAR does not relate to a GTO,
advisory, or other targeted activity.
-------------------------------------------- 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 4, 5, 11, 12, 13, 14, 15, 16, 17, and 18. These critical items
(denoted with an asterisk “*”) except Item 27 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.
3. Check:
a.
b.
If entity
If all critical* subject information is unavailable (does not include item *27)
Item 3a Check if entity: Check box 3a if the person described in Part I is an entity and not an individual. Item 3b Check
if all critical subject information is unavailable: Check box 3b if the information in Part I is unavailable for all critical
subject items except Item 27. These critical items (4, 5, 11, 12, 13, 14, 15, 16, 17, and 18) and their associated
“Unknown” fields must be left blank.
* 4. Individual’s last name or entity’s legal name
a.
(check if) unknown
Item *4 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 4 and box 4a “Unknown” must be blank if box
3b is checked. Leave item 4 blank and check box 4a “Unknown” if the individual's last name or the entity's legal name
is unknown and box 3b is not checked.
* 5. First name
a.
(check if) unknown
Item *5 First name: Enter the individual's first name. If the first name is unknown leave item 5 blank and check box 5a
“Unknown.” Leave Item 5 and box 5a “Unknown” blank if box 3a or 3b is checked.
6. Middle name
Item 6 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 3a is checked.
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7. Suffix
Item 7 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.
8. Gender
a.
b.
c.
Male
Female
Unknown
Item 8 Gender: Select options 8a Male or 8b Female if individual’s gender is known. Select option 8c “Unknown” if the
individual’s gender is unknown. Leave Item 8 blank if the subject is an entity. Item 8 (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.
9. Alternate name, e.g., AKA if individual; DBA/ trade name if entity.
Item 9 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 4-6. Do not include the acronyms AKA or DBA with the name. Multiple
Item 9 fields may be completed if multiple subject alternate names are known.
10. Occupation or type of business
a.
NAICS Code
Item 10 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 non- descriptive 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.
Item 10a NAICS Code: select the North American Industry Classification System (NAICS) code for the occupation or
type of business entered in Item 10. Batch filers should only enter codes from the list of NAICS Codes authorized for
use in the FinCEN SAR and located on the BSA E- Filing Web Site (http://bsaefiling.fincen.treas.gov/main.html) or from
the U.S. Census Bureau NAICS list at https://www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2017. If the Census
Bureau list is used filers cannot substitute a sector code (such as 11 Agriculture, Forestry, Fishing and Hunting) for an
actual three to six number NAICS Code (such as 11114 Wheat Farming).
Items *11 - *14 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 or
U.S. Territory 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 11a "Unknown." If box 3b 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.
*11. Address
a.
(check if) unknown
*12. City
a.
(check if) unknown
13. State
a.
(check if) unknown
*14. ZIP/Postal Code
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a.
(check if) unknown
*15. Country Code
a.
(check if) unknown
*16. TIN (enter number in space provided and check appropriate type below)
b.
(check if) unknown
Item *16 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 16a "Unknown" and leave Item 16 blank. Leave item 16 and box
16a “Unknown” blank if box 3b is checked. See General Instruction 9 for information on entering identifying numbers.
17. TIN type
a.
b.
c.
EIN
SSN-ITIN
Foreign
Item 17 TIN type: Identify the type of TIN recorded in Item 16. Select option 17a “EIN” if the subject has a U.S.
Employer Identification Number (EIN). Box 3a “If entity” must be checked because an EIN is assigned only to an entity.
Select option 17b “SSN-ITIN” if the subject has a U.S. Social Security Number (SSN) or Individual Taxpayer
Identification Number (ITIN). Select option 17c “Foreign” if the subject has a foreign TIN of any type. Box 3a must be
checked if the foreign subject is an entity. If 17c 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 16a “Unknown” is
checked. If a 9-digit TIN is entered in Item 17 but the TIN type is unknown, select option 17a “EIN” if the subject is an
entity and option 17b “SSN-ITIN” if the subject is an individual. TINs that are not 9 digits are presumed to be foreign,
so option 17c “Foreign” would be selected.
* 18. Form of identification for subject:
a.
b.
c.
d.
e.
f.
g.
z.
(check if) unknown
Driver’s license/state ID
Passport
Alien registration
Number
Issuing State
Country
Other (and specify type in space provided)
Item *18 Form of identification: Enter in Item 18 the information used to identify the individual or entity. Select
option 18b if the identification was a driver's license or state ID, 18c if the identification was a passport or 18d if the
identification was an alien registration. Select option 18z 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 18e "Number." Do not include formatting such as hyphens or periods. Select the appropriate state option in
field 18f "Issuing state" if the identification issuer was a U.S., Canadian, or Mexican state, territory, or province. Select
the appropriate country option in field 18f "Country" if the issuer was a country. If field 18f “Issuing state” contains an
entry, then 18g “Country” must contain “US,” “CA,” or “MX” as appropriate. Enter the data on the country that issued
the ID or where the ID was issued. 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 18g.
For example, if the issuer was the London Police Department United Kingdom would be selected in 18g. Record the
name and nature of the issuer in Part V. Enter all identification data that is available. Check box 18a “Unknown” only if
all identification information is unknown but the subject is known. Leave all fields in Item 18 blank if box 3b has been
checked. Multiple sets of Item 18 fields may be completed if multiple types of identification for a subject are known.
See General Instruction 9 for information on entering identifying numbers.
* 19. Date of birth MM/DD/YYYY
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a.
(check if) unknown
Item *19 Date of birth: If the subject is an individual enter the subject's data of birth in Item 19. Filers of FinCEN’s
discrete FinCEN SAR must use the format MM/DD/MMYY where MM = month, DD = day, and YYYY = year. Batch
filers must use the format YYYYMMDD. 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 19780200 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 19a "Unknown" and leave Item
19 blank. If box 3a or b is checked, Item 19 and box 19a “Unknown” must be blank.
20. Phone number – type
a.
b.
c.
Home
Work
Mobile
d. Fax
Item 20 Phone number – type: selected the telephone number type that applies to the telephone number recorded in
Item “21. Phone Number.” If a number is known but the type is unknown leave Item 20 blank. If a number is known
but the type is unknown, select option “a. Home” if the subject is an individual and “b. Work” if the subject is an entity.
Multiple sets of Item 20, Item 21, and Item 21a fields may be completed if multiple telephone numbers for the subject
are known
21. Phone number
a. Extension (if any)
Item 21 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 21 blank. See General Instruction 8
for information on entering telephone numbers. Multiple sets of Item 21 and Item 21a fields may be completed if
multiple telephone numbers for the subject are known.
Item 21a Ext. (if any): Enter the telephone extension associated with the subject's telephone number. Leave Item
21a blank if there is no extension or the extension is unknown.
22. E-mail address (if available)
Item 22 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 22 blank if the e-mail address is unknown. If additional e-mail
addresses are known for a subject, complete additional Item 22 fields. An e-mail address must contain the “@” sign
and a period in the text following the “@” sign. Examples: [email protected] or [email protected].
22a. Website (URL) address (if available)
Item 22a 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 22a for each URL. Leave Item 22a blank if the URL is unknown.
23. Corroborative statement to filer?
a.
b.
Yes
No
Item 23 Corroborative statement: Select "Yes" if the subject individual 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. Leave Item 23 blank of the subject is an entity
24. Relationship of the subject to an institution listed in Part III or IV (check all that apply)
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a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
z.
Institution TIN
Accountant
Agent
Appraiser
Attorney
Borrower
Customer
Director
Employee
No relationship to institution
Officer
Owner or Controlling Shareholder
Other (and specify type in space provided)
Item 24 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 81 in field 24a "Institution
EIN." Select all options 24b through 24l (but not 24j no relationship) that describe the relationship. If the relationship
is not covered by any of options 24b through 24l, select option 24z "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 any of the
financial institutions in Part III or Part IV, record box 24j "No relationship to institution” once for all institutions and
enter the Part IV filing institution’s EIN in the Item 24 “Institution TIN” field. Do not record box 24j for the subject if a
relationship exists with any institution, even when there is no relationship with other institutions." The FinCEN SAR
cannot be a joint FinCEN SAR if any of the options 24h “Director,” 24i “Employee,” 24k “Officer,” or 24l “Owner or
Controlling Shareholder” have been selected. If the subject had a relationship with a financial institution recorded in
Part III but the financial institution’s TIN was unknown, record the relationship but leave field 24a blank. If the subject
has relationships with multiple Part III and Part IV financial institutions, complete a separate set of Item 24 fields for
each financial institution. If more than one of 24h “Director,” 24i “Employee,” 24k “Officer,” or 24l “Owner or
Controlling Shareholder” is selected and/or the status or action date is different for each, an Item 24 for each must be
completed.
25. If item 24h, i, k, or l is checked, indicate status of relationship
a.
b.
c.
d.
Relationship continues
Terminated
Suspended/barred
Resigned
Item 25. If item 24h, i, k, or l is selected: If any of boxes 24h, 24i, 24k, or 24l are selected, select the appropriate Item
25 option to indicate the status of the relationship. Select option 25a if the relationship continues. Select option 25b
if the subject was terminated, 25c if the subject was suspended or barred, or 25d if the subject resigned. If multiple
sets of Item 24 fields are completed on a subject, complete an Item 25 field for each set.
26. Action date MM/DD/YYYY if 25 b, c, or d is checked
Item 26 Action date: If any of boxes 25b through 25d have been checked, enter the date the action was taken. The
date must be in MM/DD/YYYY format in a discrete FinCEN SAR and in YYYYMMDD format in a batch-filed FinCEN SAR.
Leave Item 26 blank if no action was taken. If multiple Item 24 fields were created where box 25b, 25c, or 25d was
checked, complete an Item 25 for each Item 24.
* 27. Financial Institution TIN and account number(s) affected that are related to subject, if any.
a.
b.
c.
(check if) No known accounts involved
(check if) Non-U.S. financial institution
TIN
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d.
e.
account number
(check if) closed
Item 27 Financial institution TIN and account number(s) affected that are related to the subject, if any: Enter in Item
27 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 27a "No known acct. involved" if no account related to the subject is involved in
the suspicious activity. If box 27a is checked, then all other options in Item 27 will be blank. Check box 27b "Non-US
Financial Institution" if the account is located at a foreign financial institution. Enter in field 27c 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 27d. If the account is closed, check the "Yes" 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
27d 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 27a 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 27 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.”).
28. Subject’s role in suspicious activity (if applicable)
a.
b.
c.
Purchaser/Sender
Payee/Receiver
Both a & b
Item 28 Subject's role: Record the subject's role in the suspicious activity by selecting the appropriate option. Select
option 28a "Purchaser/Sender" if the subject purchased or sent the financial instrument(s) or product(s) involved in
the suspicious activity. Select option 28b "Payee/Receiver" if the subject was the payee or receiver of the
instrument(s) or product(s). Select option 28c "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 Items 45 and
46.
Note: Item 28 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial instruments
-------------------------------------- Part II Suspicious Activity Information -----------------------------* 29. Amount involved in this report
a.
b.
(check if) Amount unknown
(check if) No amount involved
Item *29 Amount involved in this report: Enter the total amount involved in the suspicious activity for the time period
of this report. Multiple amounts will be aggregated and the total recorded in Item 29. This requirement applies even
when the amounts involve different transaction types, such as when some are deposits and some are withdrawals. All
amounts are aggregated and recorded as the total amount. If some amounts are known and some are unknown, the
known amounts are aggregated and the total is recorded in Item 29. Unknown amounts are explained in Part V. If the
amount or all amounts involved in the suspicious activity are unknown, box 29a “Amount unknown” is checked and the
Item 29 amount field will be blank. Explain in Part V why the amount or amounts are unknown. Check box 29b “No
amount involved” and leave the amount field blank if the suspicious activity did not involve any monetary amounts.
Never enter “0” in the Item 29 amount field under any circumstance. Never enter a small amount such as $1 or $5 to
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complete the amount field when that entry is not the actual amount involved. If the FinCEN SAR is a continuing report
with box 1c “Continuing activity report” checked, enter only the total of amounts that are involved for the time period
covered by this FinCEN SAR. Do not include amounts from prior FinCEN SARs in Item 29. Prior FinCEN SAR amounts
and the current FinCEN SAR total amount are aggregated in Item 31 “Cumulative amount only if box 1c (continuing
activity report) is checked.” See General Instruction 9 for information on entering amounts.
*30. Date or date range of suspicious activity for this report
a.
b.
From: MM/DD/YYYY
To: MM/DD/YYYY
Item *30 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 30a "From" and leave field 30b
"To" blank. If the suspicious activity occurred on multiple days, enter the earliest date of suspicious activity in field
30a and the most-recent date of suspicious activity in field 30b. 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/YYYY for dates in a discrete
FinCEN SAR and the format YYYYMMDD for dates in a batch-filed FinCEN SAR.
31. Cumulative amount (only applicable when”Continuing activity report” is checked in Item 1)
Item 31 Cumulative amount: Enter the cumulative amount involved in the suspicious activity in Item 31 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 31 and explain the nature of the unknown amounts in Part V. See General Instruction 10 for
information on entering amounts. Leave Item 31 blank if box 1c is not checked.
Items 32 - 41 Types of suspicious activity: Use the suspicious activity category Items 32 through 41 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.
Note: Items 32-41 are considered critical. At least one item in 32 to 41 must be checked.
32. Structuring
a.
b.
c.
d.
e.
z.
Alters or cancels transaction to avoid BSA recordkeeping requirement
Alters or cancels transaction to avoid CTR requirement
Suspicious inquiry by customer regarding BSA reporting or recordkeeping requirements
Transaction(s) below BSA recordkeeping threshold
Transaction(s) below CTR threshold
Other (specify type of suspicious activity in space provided)
33. Terrorist financing
a.
z.
Known or suspected terrorist / terrorist organization
Other (specify type of suspicious activity in space provided)
34. Fraud
a.
b.
c.
d.
ACH
Advance fee
Business loan
Check
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e.
f.
g.
h.
i.
j.
k.
l.
m.
z.
Consumer loan
Credit/Debit card
Healthcare/Public or private health insurance
Mail
Mass-marketing
Ponzi scheme
Pyramid scheme
Securities fraud
Wire
Other (specify type of suspicious activity in space provided)
35. Gaming activities
a.
b.
c.
d.
z.
Chip walking
Minimal gaming with large transactions
Suspicious use of counter checks or markers
Unknown source of chips
Other (specify type of suspicious activity in space provided)
36. Money laundering
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
z.
Exchanges small bills for large bills or vice versa
Funnel account
Suspicion concerning the physical condition of funds
Suspicion concerning the source of funds
Suspicious designation of beneficiaries, assignees or joint owners
Suspicious EFT/wire transfers
Suspicious exchange of currencies
Suspicious receipt of government payments/benefits
Suspicious use of multiple accounts
Suspicious use of noncash monetary instruments
Suspicious use of third-party transactors (straw-man)
Trade Based Money Laundering / Black Market Peso Exchange
Transaction out of pattern for customer(s)
Other (specify type of suspicious activity in space provided)
37. Identification / Documentation
a.
b.
c.
d.
e.
f.
z.
Changes spelling or arrangement of name
Multiple individuals with same or similar identities
Provided questionable or false documentation
Provided questionable or false identification.
Refused or avoided request for documentation
Single individual with multiple identities
Other (specify type of suspicious activity in space provided)
38. Other suspicious activities
a.
b.
c.
d.
Account takeover
Bribery or gratuity
Counterfeit instruments
Elder financial exploitation
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e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.
r.
s.
z.
Embezzlement/theft/disappearance of funds
Forgeries
Human smuggling
Human trafficking
Identity theft
Little or no concern for product performance penalties, fees, or tax consequences
Misuse of position or self-dealing
Suspected public/private corruption (domestic)
Suspected public/private corruption (foreign)
Suspicious use of informal value transfer system
Suspicious use of multiple transaction locations
Transaction with no apparent economic, business, or lawful purpose
Transaction(s) involving foreign high risk jurisdiction
Two or more individuals working together
Unlicensed or unregistered MSB
Other (specify type of suspicious activity in space provided)
39. Insurance
a.
b.
c.
d.
e.
f.
z.
Excessive insurance
Excessive or unusual cash borrowing against policy/annuity
Proceeds sent to or received from unrelated third party
Suspicious life settlement sales insurance (e.g. STOLIs, Viaticals)
Suspicious termination of policy or contract
Unclear or no insurable interest
Other (specify type of suspicious activity in space provided
40. Securities / Futures / Options
a.
b.
c.
d.
e.
z.
Insider trading
Market manipulation
Misappropriation
Unauthorized pooling
Wash Trading
Other (specify type of suspicious activity in space provided)
41. Mortgage fraud
a.
b.
c.
d.
e.
z.
Application fraud
Appraisal fraud
Foreclosure/Short sale fraud
Loan modification fraud
Origination fraud
Other (specify type of suspicious activity in space provided)
42. Cyber event (If reporting)
a.
b.
z.
Against Financial Institution(s)
Against Financial Institution Customer(s)
Other (specify type of suspicious activity in space provided)
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Item 42, Cyber event: Complete item 42 to indicate if the cyber event was directed against the financial institution or
its customer/account holder. Events against the institution may include, but not limited to, a digital denial of service
(DDoS), an attempt to break (hack) into the financial institutions computer system or an attempt to take over the
financial institutions “wire transfer system,” the financial institutions website, a Business E-Mail Attack (BEA), etc.
Examples of cyber events against the financial institutions customer may include the takeover (or attempted takeover)
of the customer’s account, the sending of bogus e-mails that appear to come from the customer directing various
financial transactions that do not follow the customers normal account activity, etc.
43. IP Address(es) (if available, multiples up to 99)
a. Date (MM/DD/YYYY)
b. Time Stamp (UTC) HH:MM:SS
Item 43 IP address: If known, enter the IP address of the subject’s electronic internet based contact with the financial
institution. For example, this may be the IP address used to log into the institution’s online banking page or the IP
address used to access an institution’s mobile application. In item 43a enter the date (MM/DD/YYYY format) of the
activity. In 43b enter the UTC time in (HH:MM:SS format) of the first instance of the reported IP address. Select the (+)
sign to report multiple IP address, date and time information. IP address information must be explained in the FinCEN
SAR Part V narrative. Batch filers will use the date format YYYYMMDD.
NOTE: If reporting an IP address in connection with a cyber-event, complete item 44.
Item 44. Cyber-event indicator (multiple entries up to 99)
Item 44 Cyber-event indicator: Enter the cyber-event indicator by selecting the appropriate indicator from the
dropdown list provided and enter the supporting information in the associated text field (an indicator not listed may
be entered in the “z” Other text fields. Select the (+) sign to report multiple event indicators. Each cyber-event
indicator and its associated text field is limited to 99 entries. Cyber-event indicator information must be explained in
the BFinCEN SAR Part V narrative. See General Instruction 13 for additional information on reporting cyber-related
events.
44a. Command and Control IP address
44a1 Event value text field (each entry of 44a must have a corresponding event value
text field).
44a2 Event value text field (Date associated with the value in 44a1).
44a3 Event value text field (Timestamp associated with the value in 44a1).
44b. Command & Control URL/Domain
44b1 Event value text field. (each entry of 44b must have a corresponding event value
text field)
44c. Malware MD5, Malware SHA-1, or Malware SHA-256.
44c1 Event value text field. (each entry of 44c must have a corresponding event value
text field)
44d. Media Access Control (MAC) Address
44d1 Event value text field (each entry of 44d must have a corresponding event value
text field).
44e. Port
44e1 Event value text field. (each entry of 44e must have a corresponding event value
text field)
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44f. Suspicious e-mail address
44f1 Event value text field. (each entry of 44f must have a corresponding event value
text field)
44g. Suspicious filename
44g1 Event value text field. (each entry of 44g must have a corresponding event value
text field)
44h. Suspicious IP Address
44h1 Event value text field. (each entry of 44h must have a corresponding event value
text field)
44h2 Event value Date associated with the value in 44h1 (discrete format MM/DD/YYYY
and batch format YYYYMMDD).
44h3 Event value Timestamp associated with the value in 44h1.
44i. Suspicious URL/Domain
44i1 Event value text field. (each entry of 44i must have a corresponding event value
text field)
44j. Targeted system
44j1 Event value text field. (each entry of 44j must have a corresponding event value
text field)
44z. Other
44z Text description of Other value
44z1 Event value text field. (each entry of 44z must have a corresponding event
value text field)
45. Were any of the following product type(s) involved in the suspicious activity? Check all that apply:
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
o.
p.
q.
r.
Bonds/Notes
Commercial mortgage
Commercial paper
Credit card
Debit card
Deposit account
Forex transactions
Futures/Options on futures
Hedge fund
Home equity line of credit
Home equity loan
Insurance/Annuity products
Microcap securities
Mutual fund
Options on securities
Prepaid access
Residential mortgage
Security futures products
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s.
t.
z.
Stocks
Swap, hybrid or other derivative
Other (specify type in space provided)
Item 45 Product types involved in suspicious activity: Check all Item 45 boxes that apply to record the product
type(s) involved in the suspicious activity. Option 45f ‘Forex transactions” includes all foreign exchange transactions
both on and off-exchange, including futures and options on foreign exchange. Option 45g “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 45s “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 45a through 45s, check box 45z "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 48 “Product/instrument description” or in Part V. If there are multiple product types not covered by Item 45,
record one in Item 45z "Other (List below)” and all others in Part V.
46. Were any of the following instrument type(s)/payment mechanism(s) involved in the suspicious activity? Check all
that apply:
a.
b.
c.
d.
e.
f.
g.
h.
i.
z.
Bank/cashier’s check
Foreign currency
Funds transfer
Gaming instruments
Government payment
Money orders
Personal/Business check
Travelers checks
U.S. Currency
Other (specify type in space provided)
Item 46 Instrument types involved in suspicious activity: Check all Item 46 boxes that apply to record the instrument
type(s) involved in the suspicious activity. If the instrument type is not covered by options 46a through 46i, check
box 46z "Other (List below)" and enter a brief description in the associated text field. If necessary provide a moredetailed description of the instrument type in Part V. If there are multiple instrument types not covered by Item 46,
record one in Item 46 "Other (List below)” and all others in Part V.
47. Commodity type (if applicable)
Item 47 Commodity type: If a commodity is involved in the suspicious activity, record the commodity type in Item
47. Multiple Item 47 fields should be completed if multiple commodity types are involved in the suspicious activity.
48. Product/Instrument description (if needed) (multiple entries up to 99)
Item 48 Product description: Provide a description of the product recorded in Item 45 or instrument recorded in
Item 46 if necessary for a more-complete understanding of the suspicious activity. Multiple Item 48 fields should be
completed if multiple products or instruments requiring a description are involved in the suspicious activity.
49. Market where traded
Item 49 Market where traded: Enter in Item 49 the three to five-letter code for the market where a commodity
recorded in Items 45 or 47 was traded. Multiple Item 49 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.
50. CUSIP number
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Item 50 CUSIP® number: Enter in Item 50 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 50
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 68 through 74. Information for up to 99 branches can be
recorded in a single FinCEN 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).
*51. Type of financial institution
a.
b.
c.
d.
e.
f.
g.
z.
Casino/Card club
Depository institution
Insurance company
MSB
Securities/Futures
Loan or Finance Company
Housing GSE
Other (specify type of institution in space provided)
Item *51 - Type of financial institution: Select the appropriate type of financial institution that best describes the
financial institution recorded in Item 51. If none of those options apply, select “Other” and enter a brief description
in the associated text field. If necessary, include a more- detailed description in Part V.
NOTE: 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.
*52. Primary Federal Regulator
a.
b.
c.
d.
e.
f.
g.
h.
CFTC
Federal Reserve
FDIC
IRS
NCUA
OCC
SEC
Not Applicable
Item *52 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 51 option
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“Casino/Card Club,” “Insurance Company,” or “MSB” was selected, the Item 52 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.”
53. If item 51a is checked, indicate type of gaming institution (check only one)
a.
b.
c.
z.
State licensed casino
Tribal authorized casino
Card club
Other (specify type of gaming institution in space provided)
Item 53 Gaming institution type: If option 51a 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 53a through 53c are appropriate, check box 53z "Other" and provide a brief description in the
associated text field. If necessary, include a more detailed description in Part V.
54. If item 51e is checked, indicate type of Securities and Futures institution or individual where activity occurred check the boxes of all types that apply to this report.
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
z.
Clearing broker – securities
Execution-only broker securities
Futures commission merchant
Holding company
Introducing broker - commodities
Introducing broker - securities
Investment adviser
Investment company
Retail foreign exchange dealer
Self-clearing broker-securities
Subsidiary of financial/bank holding company
Other (specify type of institution or individual in space provided)
Item 54 Securities and futures type: If option 51e was checked indicating the financial institution is part of the
securities and futures industries, check all boxes that apply to the reported suspicious activity. If none of options
54a through 54k apply, check box 54z "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 more-detailed
description in Part V.
55. Financial institution identification number
a.
b.
c.
d.
e.
f.
g.
Central Registration Depository (CRD) number
Investment Adviser Registration Depository (IARD) number
National Futures Association (NFA) number
Research, Statistics, Supervision, and Discount (RSSD) number
Securities and Exchange Commission (SEC) number
National Association of Insurance Commissioners (NAIC Code)
Mortgage (NMLS ID)
z. Identification number
Item 55 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,
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National Association of Insurance Commissioners (NAIC Code), Mortgage (NMLS ID) 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 55h. See General Instruction 8 for information on entering identifying numbers.
56. Financial institution’s role in transaction (if applicable)
a.
b.
c.
(check if) Selling location
(check if) Paying location
(check if) Both a & b
Item 56 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 45 or 46. Check the box “Paying location”
if the customer received payment from the Part III financial institution for the products or instruments recorded in
Items 45 or 46. 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 45 or 46.
Note: Item 56 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial
instruments.”
*57. Legal name of financial institution
a. (check if) unknown
Item 57 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. Record as the legal name the full name of an
individual, such as a sole proprietorship, acting as a financial institution. Enter the individual’s name in (first name)
(middle name) (last name) or equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc. Check box 57a
“Unknown” if the legal name is unknown and leave Item 57 blank.
58. Alternate name, e.g., AKA if individual; DBA/trade name if entity
Item 58 Alternate name: If the financial institution recorded in Item 58 has a separate doing business as (DBA)
name, enter that name here. If an individual recorded in Item 58 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.
* 59. TIN
a. (check if) unknown
Item 59 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the financial institution or
individual recorded in Item 57. See General Instruction 8 for information on entering identifying numbers. Check
box 59a “Unknown” if the TIN is unknown and leave Item 59 blank.
60. TIN type
a. EIN
b. SSN-ITIN
c. Foreign
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Item 60 TIN type: Select the option for the type of TIN entered in Item 59. If the TIN in Item 59 is unknown and the
Item 57 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 individual. If the financial institution has a foreign address and the TIN is
unknown, select “Foreign.”
Items *61 - *65 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 63 State blank if the state is unknown or the country is not the U.S. or a U.S. Territory, Canada, or
Mexico. See General Instruction 6 and the Part III introductory instructions for additional information on entering
address data.
*61. Address
a. (check if) unknown
*62. City
a. (check if) unknown
63. State
*64. ZIP/Postal Code
a. (check if) unknown
*65. Country
66. Internal control/file number
Item 66 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.
67 Loss to financial institution (if applicable)
Item 67 Loss to financial institution: If the financial institution has suffered a loss because of the suspicious activity,
record the amount of loss in Item 67. 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 67 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 29 “Amount involved in this report.” See General Instruction 10 for information on entering
amounts.
68. Branch’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 68 Branch’s role: Check the box “Selling location” if the branch sold the products or instruments recorded in
Items 45 or 46 to a customer. Check the box “Paying location” if a customer received payment from the branch for
the products or instruments recorded in Items 45 or 46. 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 45 or 46. 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 68 must be prepared for each branch.
Note: Item 68 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial
instruments.
Items *69 and 71-74 Branch address items: See the instructions for Items *61 - *65, the Part III introductory
instructions, and General Instruction 6 for information on entering branch address data. If a branch address item is
unknown, leave that item blank. Item 74 “Country” cannot be blank if any other branch address information is
recorded. If no branch was involved in the suspicious activity or the branch country is unknown, check box 69a 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.
69. Address of branch or office where activity occurred
a. If no branch activity involved, check this box
70. RSSD number (of the Branch)
Item 70 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 70 for each branch for which the RSSD
number is known.
71. City
72. State
73. ZIP/Postal Code
*74. Country
------------------------------- Part IV Filing Institution Contact Information ----------------------------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).
*75. Primary Federal Regulator (instructions specify banking agencies, SEC, CFTC, IRS)
a. Commodities Futures Trading Commission (CFTC)
b. Federal Reserve Board (FRB)
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c.
d.
e.
f.
g.
h.
z.
Federal Deposit Insurance Corporation (FDIC)
Internal Revenue Service (IRS)
National Credit Union Administration (NCUA)
Office of the Comptroller of the Currency (OCC)
Securities and Exchange Commission (SEC)
Federal Housing Finance Agency (FHFA)
Not Applicable.
Item *75 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 79 option “Casino/Card
Club,” “Insurance Company,” or “MSB” is selected, the Item 75 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.”
*76. Filer name (Holding company, lead financial institution, or agency, if applicable).
Item *76 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.
*77. TIN
Item *77 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the financial institution or
individual recorded in Item 76. See General Instruction 8 for information on entering identifying numbers.
*78. TIN type
a. EIN
b. SSN/ITIN
c. Foreign
Item *78 - TIN type: Record the type of TIN entered in Item 77 by selecting the appropriate option.
*79. Type of financial institution
a.
b.
c.
d.
e.
f.
g.
z.
Casino/Card club
Depository institution
Insurance company
MSB
Securities/Futures
Loan or Finance Company
Housing GSE
Other (specify type of institution in space provided)
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Item *79 - Type of financial institution: Select the appropriate type of financial institution that best describes the
filing institution recorded in Item 76. If none of those options apply, select “Other” and enter a brief description in
the associated text field. If necessary, include a more- detailed description in Part V.
NOTE: 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.
80. Type of Securities and Futures institution or individual filing this report - check the boxes of all types that apply to
this report.
a.
b.
c.
d.
e.
f.
g.
h.
i.
j.
k.
l.
m.
n.
z.
Clearing broker - securities
CPO/CTA
Execution-only broker securities
Futures commission merchant
Holding company
Introducing broker - commodities
Introducing broker - securities
Investment adviser
Investment company
Retail foreign exchange dealer
Self-clearing broker-securities
SRO Futures
SRO Securities
Subsidiary of financial/bank holding company
Other (specify type of institution or individual in space provided)
Item 80 - Securities and futures type: If option 80e “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 80a through
80nl apply, check box 80z "Other" and record a brief description of the type in the associated text field. If necessary,
include a more-detailed description in Part V.
81. Filing institution identification number
a.
b.
c.
d.
e.
f.
g.
Central Registration Depository (CRD) number
Investment Adviser Registration Depository (IARD) number
National Futures Association (NFA) number
Research, Statistics, Supervision, and Discount (RSSD) number
Securities and Exchange Commission (SEC) number
National Association of Insurance Commissioners (NAIC Code)
Mortgage (NMLS ID)
z. Identification number
Item 81 - Filing institution identification number: See instructions for Item 55.
Items 82-86 - Address: See instructions for Items 61 through 65.
*82. Address
* 83. City
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*84. State
* 85. ZIP/Postal Code
* 86. Country
87. Alternate name, e.g., AKA if individual; DBA/ trade name if entity. See instructions
for Item 58.
88. Internal control/file number: See instructions for Item 66.
89. LE contact agency
Item 89 - LE contact agency: Enter the name of the law enforcement agency, if any, which has been informed of the
suspicious activity.
NOTE: If more than one LE agency has been contacted about the suspicious activity, record the information on one
agency in Items 89-92 and the information on additional agencies in Part V.
90. LE contact name
Item 90 - LE contact name: Enter the name of the person contacted at the law enforcement agency.
91. LE contact phone number
Item 91 - LE contact phone number: Enter the law enforcement contact telephone number. See General Instruction 7
for information on entering telephone numbers.
91a. Extension (if any)
Item 91a - Extension: Enter the extension, if any, of the law enforcement contact telephone number
92. LE contact date
Item 92 – 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.
Discrete filers will use the format MM/DD/YYYY while batch filers will use the format YYYYMMDD.
*93. Filing institution contact office
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Item 93 - 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.
*94. Filing institution contact office phone number including area code
a. Extension, if any
Item 94 - Filing institution contact office phone number: Enter the contact office telephone number. See General
Instruction 7 for additional instructions on entering telephone numbers.
Item 94a - Extension: Enter the extension, if any, of the contact office telephone number.
*95. Date filed
Item 95 - Date filed: Enter the date the FinCEN SAR is filed. This date will be entered automatically when a discrete
FinCEN SAR is electronically filed. Batch filers will report this date in YYYYMMDD format.
---------------------------- * 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.
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•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
•
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
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.
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.
Do not include tabular data in a FinCEN SAR narrative. Such data should be reported in an
appropriate comma separated values attachment.
If this SAR contains information provided by another financial institution under the 314(b) Voluntary
Information Sharing Program, include in the narrative the statement “This SAR contains 314(b) data.
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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10. Attachment D – Secure Data Transfer Mode Filers
FinCEN provides the ability for filers to submit the FinCEN SAR XML batch file securely via the Internet using a VPN
device or Connect:Direct* software. This method of filing is referred to as Secure Data Transfer Mode (SDTM). SDTM
allows for a secure, system to system mechanism for transferring batch submissions from your organization’s internal
server to the BSA E-Filing server. The batch submission process can be automated such that user
intervention/involvement is minimized. There is no interaction with the BSA E-Filing system web site for the upload of
the batch file but the BSA E-Filing system web site is used to track the status of the submissions.
For filers using this option for filing, SDTM filers can submit a single file containing the FinCEN SAR XML batch data.
The file naming convention is as follows:
Position
Description
Requirement
Form type
Form type being submitted (i.e. SARXST)
Form type (SARXST) required in 1st
position (case sensitive).
.
Filename delimiter
Delimiter required.
Filename delimiter
Delimiter required.
Unique value
.
SDTM_UID**
.
xml
Value determined by filer (must not
contain periods or spaces)
The User ID associated with the SDTM
account
Filename delimiter
File extension
Value required in 2nd position (unique
date-timestamp recommended)
Complete SDTM_UID required in 3rd
position (case sensitive).
Delimiter required.
Extension required (not case sensitive).
EXAMPLE: SARXST.20170609153015.ABCPreparingFirm.xml
For more information on how to setup an SDTM connection, please direct them to the BSA E-Filing Help via the
Support Request Form. The Help Desk hours of operation are M-F 8:00 AM to 6:00 PM, Eastern Time (closed on
federal holidays).
*Please be advised that IBM’s Connect:Direct software is scheduled to be replaced with IBM’s Sterling File Gateway software in 2020.
**You can verify your filing organization’s SDTM_UID by having a Supervisory User for your organization login to the BSA E-Filing
System and select “Manage Users.”
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11. Attachment E – Supporting Documentation (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.
Record the supporting document file name for each FinCEN SAR XML within the batch
Record the element, along with the subelement, for each FinCEN SAR Activity within the XML batch associated with an attachment. Record the full
name of the corresponding CSV file within the OriginalAttachmentFileName element.
2.
Record the counts for the total number of attachments and FinCEN SAR XML activities with
attachments with the batch
Record the following attributes and counts within the EFilingBatchXML element in the XML batch:
3.
•
ActivityAttachmentCount. The count of all elements in the batch where the
element is recorded with a value referencing the file name of the
FinCEN SAR attachment
•
AttachmentCount. The count of all elements in the batch that
contain a value referencing the file name of the FinCEN SAR attachment
Include all attachments in a single zip file with the FinCEN SAR XML activity sequence number
appended to each attachment file name
•
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.
•
For each csv attachment file within the zip file, append the corresponding sequence number (i.e.
“SeqNum” value associated with the FinCEN SAR Activity in the XML batch as follows:
_.csv
For example:
1_BankofUSBatchAttachment.csv
The above example indicates that within the FinCEN SAR XML batch, Activity SeqNum=”1” contains
the element with the value of “BankofUSBatchAttachment.csv”.
4.
Attach the attachments zip file to the FinCEN SAR XML Batch Form prior to submission
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Once all required fields are complete and your FinCEN SAR XML batch has been attached to the FinCEN SAR
XML Batch Form, locate the Add File button for attachments in order to add your attachment zip file to the
FinCEN SAR XML Batch Form. Once the attachment file is attached, you may sign the FinCEN SAR Batch Form
with your PIN, save, and submit.
ATTENTION: Secure Data Transfer Mode (SDTM) Filers
Filers who transmit the FinCEN SAR XML batch data via secure server-to-server connection may submit a single
ZIP file containing the FinCEN SAR XML batch file along with the corresponding attachment zip file. This single
ZIP file is composed of one FinCEN SAR XML batch file and one attachment ZIP file. The attachment ZIP file shall
follow the same attachment requirements described above. The single ZIP file name must start with “SARXST.”
and end with “.ZIP”. For example: SARXST.SARXML_batch.ZIP. FinCEN SAR XML SDTM batch files without any
attachment shall follow the naming convention described in Attachment D of this guide.
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| File Type | application/pdf |
| Author | Gardner, Matthew (Contractor) |
| File Modified | 2020-07-07 |
| File Created | 2020-07-07 |