FinCEN Form 111 - Suspicious Activity Report

Under 31 U.S.C. 5318(g), the Secretary of the Treasury is authorized to require financial institutions to report any suspicious transaction relevant to a possible violation of law or regulation. Regulations implementing 31 U.S.C. 5318(g) are found at 31 CFR 1020.320, 1021.320, 1022.320, 1023.320, 1024.320, 1025.320, 1026.320, 1029.320, and 1030.320. These transactions are reported on FinCEN Report 111- Suspicious Activity Report (SAR). Financial institutions submit SARs to FinCEN electronically via the BSA E-filing system. The SAR regulatory reporting requirements are currently covered under the following OMB control numbers: 1506-0001 (31 CFR 1020.320 – Reports by banks of suspicious transactions); 1506-0006 (31 CFR 1021.320 – Reports by casinos of suspicious transactions); 1506-0015 (31 CFR 1022.320 – Reports by money services businesses of suspicious transactions); 1506-0019 (31 CFR 1023.320 – Reports by brokers or dealers in securities of suspicious transactions, 31 CFR 1024.320 – Reports by mutual funds of suspicious transactions, and 31 CFR 1026.320 – Reports by futures commission merchants and introducing brokers in commodities of suspicious transactions); 1506-0029 (31 CFR 1025.320 – Reports by insurance companies of suspicious transactions); and 1506-0061 (31 CFR 1029.320 – Reports by loan or finance companies of suspicious transactions). OMB control number 1506-0065 applies to FinCEN Report 111 – SAR. An administrative burden of one hour is assigned to each of the SAR regulation OMB control numbers in order to maintain the requirements in force. The reporting and recordkeeping burdens are reflected in FinCEN Report 111 – Suspicious Activity Report (“SAR”) under OMB control number 1506-0065. The rationale for assigning one burden hour to each of the SAR regulation OMB control numbers is that the annual burden hours would be double counted if FinCEN estimated burden in the industry SAR regulation OMB control numbers and in the SAR OMB control number.

The latest form for FinCEN Form 111 - Suspicious Activity Report expires 2023-09-30 and can be found here.