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BSA
Requirements |
| Money Services Business (MSB)
- Suspicious Activity Reporting
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Certain money
services businesses (MSBs) are required to report suspicious activity.
The following MSBs are subject to the suspicious
activity reporting (SAR) requirement:
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Money transmitters
Money order - issuers, sellers and redeemers
Traveler's check - issuers, sellers and redeemers
US Postal Service
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A report must be filed when a transaction that is conducted by, at
or through the MSB is both:
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Suspicious, and
$2,000 or more
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Suspicious. A transaction must be reported if
the MSB knows, suspects or has reason to suspect that the transaction
(or a 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, or is
- Designed to evade the requirements of the
Bank Secrecy Act, whether through structuring or
other means, or
- Serves no business or apparent lawful purpose,
and the reporting business knows of no reasonable explanation
for the transaction after examining all available facts.
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Filing. A SAR must be filed using a
SAR MSB form. MSBs have
30 days after becoming aware of
a suspicious transaction to complete and
file the form.
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Retention. A copy of the filed form
and supporting documentation
must be retained for a period of five years from the date of filing.
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Disclosure Prohibited.
MSBs (including MSB employees) are prohibited from disclosing to a
person involved in the transaction that a suspicious activity
report has been filed. Further, each MSB (including each MSB
employee) is protected from civil liability for any SAR filed by the MSB.
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Penalties. Civil and
criminal penalties may be imposed for willful violation of the
SAR requirement.
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