Notices to Members

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Notice I-12-08

June 5, 2012

The Financial Crimes Enforcement Network (FinCEN) Requires Electronic Filing of SARs and CTRs

On February 29, 2012, FinCEN published a Final Notice requiring that all financial institutions subject to the Bank Secrecy Act (BSA) begin electronically filing certain BSA reports effective July 1, 2012. A copy of the final notice appears at http://www.gpo.gov/fdsys/pkg/FR-2012-02-29/pdf/2012-4756.pdf. As a result, beginning July 1, 2012, FCMs must electronically file Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) and IBs must electronically file SARs through FinCEN's BSA E-Filing System. For those FCMs and IBs that have not enrolled in the BSA E-Filing System, please access the following link for enrollment information: http://www.fincen.gov/whatsnew/pdf/E-File_Brochure.pdf [broken hyperlink removed 1/4/22]. Note that the enrollment process can take from 5 to 7 days.

FCMs and IBs may currently file Reports of Foreign Bank and Financial Accounts (FBARs) using FinCEN's E-Filing System. However, the deadline for mandatory E-Filing for those reports is July 1, 2013.

General E-Filing FAQs can be found at: http://www.fincen.gov/forms/e-filing/Efiling_FAQs.html [broken hyperlink removed 1/4/22].

Questions concerning the E-Filing requirement should be directed to Erin Walls, Field Supervisor, Compliance at ewalls@nfa.futures.org or Sharon Pendleton, Director, Compliance at spendleton@nfa.futures.org.