Chapter 9: Financial Privacy

Suspicious Activity Reports and BSA Enforcement

Institutions must file a Suspicious Activity Report (SAR) with FinCEN for insider crimes regardless of amount, crimes of $5,000+ with a suspect, crimes of $25,000+ without a suspect, and suspected money-laundering currency transactions of $5,000+. BSA penalties include large fines and imprisonment, extending to crypto mixers.

How this supports CIPP/US study

Use this lesson to separate sectoral scope, data type and regulated entity before testing an exception. Continue with the CIPP/US practice exam.

When a SAR must be filed
SituationThreshold
Insider committing or aiding a crimeAny dollar amount
Possible crime with a substantial basis to identify a suspect$5,000 or more
Possible crime with no substantial basis to identify a suspect$25,000 or more
Suspected currency transactions involving money laundering or act violation$5,000 or more (aggregated)
Insider = no threshold

When an insider is suspected of committing or aiding a crime, a SAR is required regardless of dollar amount. The $5,000 and $25,000 thresholds turn on whether a suspect can be identified.

Key terms - quick answers

What is “Suspicious activity report (SAR)”?
A report financial institutions must file with FinCEN in defined situations to alert the government to potentially suspicious transactions.

Sources and study method

This independent lesson uses active recall, spaced retrieval and scenario practice. Read the full study method.