As promised earlier this month on July 27th, 2018, FinCEN released the following changes to the BSA E-Filing System production environment:
- FinCEN posted the new discrete entry form version (v1.2) of the FinCEN Suspicious Activity Report (SAR) for download/submission;
- FinCEN began accepting batch files containing the new FinCEN SAR in the new FinCEN 2.0 XML schema format;
- FinCEN updated the FinCEN CTR XML batch schema to prohibit certain unwanted characters/formatting for all elements values in the batch, specifically leading and trailing spaces, carriage returns, line feeds, and horizontal tabs. If any value contains one or more instances of the above unwanted characters/formatting, the batch submission will be REJECTED by the application beginning July 27th, 2018 (these restrictions will also be applied to FinCEN SAR and FinCEN FBAR XML batch submission).
FinCEN will continue to accept the existing FinCEN SAR discrete form as well as the existing ASCII based batch format; however, beginning on January 1, 2019, FinCEN will only accept the new FinCEN SAR discrete form and the new XML based batch format.
FinCEN SAR Discrete Filer Impact
On July 27th, 2018, the new discrete entry form (v1.2) replaces the existing form (v1.1) on the BSA E-Filing System. To access the new discrete entry form, login to the BSA E-Filing System, select “Report 111 – SAR, and click “Open New Form”. FinCEN will continue to accept all previously downloaded versions of the discrete entry SAR form (v1.0-1.1) until January 1, 2019, at which time only the new version of the form (v1.2) will be accepted.
FinCEN SAR Batch Filer Impact
On July 27th, 2018, a new batch entry form (v1.2) designed to accept a FinCEN SAR batch file in XML format is available on the BSA E-Filing System. To access the new batch entry form, login to the BSA E-Filing System, select “Report 111 – SARXBatch, and click “Open New Form”. FinCEN will continue to accept the existing FinCEN SAR in ASCII batch format (Report 111 – SARBatch) until January 1, 2019, at which time only the new FinCEN SAR in XML batch format (Report 111 – SARXBatch) will be accepted.
Deborah Crawford will provide detailed information about the new form in a webinar on September 24, 2018 entitled Suspicious Activity Reporting: New Form and Developing Issues. For more information or to register please visit https://mycomplianceresource.com/event-registration/?ee=185