Those who file FinCEN SARs and CTRs in batches have less than a year to make their systems compliant with new standards announced yesterday by FinCEN.
The Financial Crimes Enforcement Network (FinCEN) has released Electronic Filing Requirements For FinCEN's Currency Transaction Report (CTR) and Electronic Filing Requirements For FinCEN's Suspicious Activity Report (SAR).
These technical specifications are to be used to develop batch files of FinCEN's new CTR (FinCEN Report 112) and SAR (FinCEN Report 111) for upload or transmission to the BSA E-Filing System.
The BSA E-Filing System will begin accepting batch filings matching the specifications for the new CTR and SAR December 2011. Discrete filing versions of the new CTR and SAR will also be available in December 2011.
Batch filers will have until 30 June, 2012, to update their systems to these new specifications.
All institutions that batch file the current CTR, CTR-C, SAR-DI, SAR-SF, SAR-MSB, or SAR-C will have to convert their systems to file the new CTR and SAR.
FinCEN will make other filing technical specifications available in the near future. Specifications for FinCEN's new Designation of Exempt Person (DOEP) (FinCEN Report 110) will be published soon; the BSA E-Filing System will begin accepting the new batch-filed DOEP at a later date.
Documents:
http://bsaefiling.fincen.treas.gov/news/FinCENCTRElectronicFilingRequirements.pdf
http://bsaefiling.fincen.treas.gov/news/FinCENSARElectronicFilingRequirements.pdf
By the way, FinCEN is also organising a free on-line "webinar" - but users of non-Microsoft or Apple systems need not apply: FinCEN says other systems won't work.