CAMS · Question #942
According to PinCEN. when a financial institution (PI) identities a suspicious activity that necessitates suspicious activity report (SAR) filing, the SAR supporting documentation should (Select Two.)
The correct answer is A. include all documents or records that assisted the Fl in making the determination that the activity C. have written policies and procedures to maintain supporting documentation. FinCEN requires that SAR supporting documentation include all records used in the suspicious activity determination and that institutions maintain written policies and procedures for retaining such documentation.
Question
According to PinCEN. when a financial institution (PI) identities a suspicious activity that necessitates suspicious activity report (SAR) filing, the SAR supporting documentation should (Select Two.)
Options
- Ainclude all documents or records that assisted the Fl in making the determination that the activity
- Balways be limited to account name, account details, and transaction records.
- Chave written policies and procedures to maintain supporting documentation.
- Dbe saved in a single separate file with hard copies stored in a fireproof cabinet.
How the community answered
(56 responses)- A75% (42)
- B9% (5)
- D16% (9)
Why each option
FinCEN requires that SAR supporting documentation include all records used in the suspicious activity determination and that institutions maintain written policies and procedures for retaining such documentation.
FinCEN guidance specifies that SAR supporting documentation must include all documents, records, and information that assisted the financial institution in determining that the activity was suspicious, ensuring a complete evidentiary record is preserved.
Limiting documentation only to account name, account details, and transaction records is insufficient under FinCEN guidance, which requires all relevant materials - including correspondence, background research, and due diligence records - that informed the SAR filing decision.
FinCEN also requires that financial institutions have written policies and procedures governing how SAR supporting documentation is maintained, ensuring consistency, auditability, and regulatory compliance across the organization.
FinCEN does not prescribe a specific physical storage format such as a single file or fireproof cabinet; the requirement is for adequate retention and retrievability of documentation, not a mandated physical storage method.
Concept tested: FinCEN SAR supporting documentation retention requirements
Source: https://www.fincen.gov/resources/statutes-regulations/guidance/suspicious-activity-report-sar-activity-review
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