Advanced Compliance Technology, Inc. files a SAR for any transaction at or through Advanced Compliance Technology, Inc. that involves $2,000 or more. File when the transaction involves funds from illegal activity. File when the transaction is designed to evade BSA requirements. File when the transaction serves no apparent lawful purpose. File when the transaction facilitates criminal activity.
\nStaff escalate suspicious transactions to the BSA/AML Compliance Officer the same business day. The BSA/AML Compliance Officer reviews all available facts, the customer record, and any prior SAR history. The BSA/AML Compliance Officer then decides whether to file. Document the decision and the rationale regardless of outcome. Documentation creates a defensible record for examination.
\nFile FinCEN Form 111 via BSA E-Filing within 30 calendar days of the date of initial detection. When no suspect is identified at the time of detection, the BSA/AML Compliance Officer may delay filing while attempting to identify a suspect. The outer deadline is 60 calendar days from initial detection. A firm outer deadline prevents investigations from stalling indefinitely through repeated delay.
\nWhen suspicious activity is ongoing, file a continuing activity SAR every 90 days. Each continuing SAR must cite the original SAR filing. Citing the original SAR connects the ongoing pattern to the initial detection record.
\nWhen the activity requires immediate law enforcement attention, contact the appropriate agency by telephone. Make that contact before or at the same time as the SAR filing. Concurrent notification allows law enforcement to act without delay caused by the filing timeline.
\nRetain the SAR copy and all supporting documentation for five years from the filing date. Five-year retention satisfies examination requirements and supports potential law enforcement inquiries.
\nNo employee or agent of Advanced Compliance Technology, Inc. may disclose a SAR or reveal that a SAR has been filed. This prohibition protects the integrity of ongoing financial crime investigations. If a subpoena demands a SAR or related records, decline production. Notify FinCEN promptly after receiving the subpoena. SARs filed in good faith carry statutory protection from civil liability.
\nAdvanced Compliance Technology, Inc. files a CTR for each transaction in currency that exceeds $10,000. Multiple currency transactions by or on behalf of the same person on the same business day are aggregated. Aggregation applies across all Advanced Compliance Technology, Inc. locations. Aggregation prevents customers from splitting transactions across branches to avoid reporting. When the aggregate total exceeds $10,000, the transaction is reportable.
\nTellers collect the customer's name, address, date of birth, and government-issued photo ID number before completing the transaction. The BSA/AML Compliance Officer prepares and files FinCEN Form 112 via BSA E-Filing within 15 calendar days of the transaction date. Retain the CTR copy for five years from the filing date.
\nFile FinCEN Form 105 for any physical transport of currency or monetary instruments exceeding $10,000 into or out of the United States. Federal law requires filing at the time of transport. Florida requires filing via BSA E-Filing within 15 calendar days of the transport date.
\nNo person may structure transactions to evade BSA reporting requirements. No employee of Advanced Compliance Technology, Inc. may cause Advanced Compliance Technology, Inc. to fail to file a required report. No employee may file a materially incomplete report. When a teller detects indicators of structuring, the teller reports to the BSA/AML Compliance Officer immediately. The BSA/AML Compliance Officer evaluates the activity for SAR filing. Structuring is itself a reportable event.
\nFlorida imposes criminal penalties for structuring specific to money services businesses. Structuring amounts above $300 is a third-degree felony. Structuring amounts above $20,000 is a second-degree felony. Structuring amounts above $100,000 is a first-degree felony. These penalties apply to any person, including employees who assist in structuring.
", "narration_text": "Advanced Compliance Technology, Inc. files a SAR for any transaction at or through Advanced Compliance Technology, Inc. that involves $2,000 or more. File when the transaction involves funds from illegal activity. File when the transaction is designed to evade BSA requirements. File when the transaction serves no apparent lawful purpose. File when the transaction facilitates criminal activity.\r\n\r\nStaff escalate suspicious transactions to the BSA/AML Compliance Officer the same business day. The BSA/AML Compliance Officer reviews all available facts, the customer record, and any prior SAR history. The BSA/AML Compliance Officer then decides whether to file. Document the decision and the rationale regardless of outcome. Documentation creates a defensible record for examination.\r\n\r\nFile FinCEN Form 111 via BSA E-Filing within 30 calendar days of the date of initial detection. When no suspect is identified at the time of detection, the BSA/AML Compliance Officer may delay filing while attempting to identify a suspect. The outer deadline is 60 calendar days from initial detection. A firm outer deadline prevents investigations from stalling indefinitely through repeated delay.\r\n\r\nWhen suspicious activity is ongoing, file a continuing activity SAR every 90 days. Each continuing SAR must cite the original SAR filing. Citing the original SAR connects the ongoing pattern to the initial detection record.\r\n\r\nWhen the activity requires immediate law enforcement attention, contact the appropriate agency by telephone. Make that contact before or at the same time as the SAR filing. Concurrent notification allows law enforcement to act without delay caused by the filing timeline.\r\n\r\nRetain the SAR copy and all supporting documentation for five years from the filing date. Five-year retention satisfies examination requirements and supports potential law enforcement inquiries.\r\n\r\nNo employee or agent of Advanced Compliance Technology, Inc. may disclose a SAR or reveal that a SAR has been filed. This prohibition protects the integrity of ongoing financial crime investigations. If a subpoena demands a SAR or related records, decline production. Notify FinCEN promptly after receiving the subpoena. SARs filed in good faith carry statutory protection from civil liability.\r\n\r\nAdvanced Compliance Technology, Inc. files a CTR for each transaction in currency that exceeds $10,000. Multiple currency transactions by or on behalf of the same person on the same business day are aggregated. Aggregation applies across all Advanced Compliance Technology, Inc. locations. Aggregation prevents customers from splitting transactions across branches to avoid reporting. When the aggregate total exceeds $10,000, the transaction is reportable.\r\n\r\nTellers collect the customer's name, address, date of birth, and government-issued photo ID number before completing the transaction. The BSA/AML Compliance Officer prepares and files FinCEN Form 112 via BSA E-Filing within 15 calendar days of the transaction date. Retain the CTR copy for five years from the filing date.\r\n\r\nFile FinCEN Form 105 for any physical transport of currency or monetary instruments exceeding $10,000 into or out of the United States. Federal law requires filing at the time of transport. Florida requires filing via BSA E-Filing within 15 calendar days of the transport date.\r\n\r\nNo person may structure transactions to evade BSA reporting requirements. No employee of Advanced Compliance Technology, Inc. may cause Advanced Compliance Technology, Inc. to fail to file a required report. No employee may file a materially incomplete report. When a teller detects indicators of structuring, the teller reports to the BSA/AML Compliance Officer immediately. The BSA/AML Compliance Officer evaluates the activity for SAR filing. Structuring is itself a reportable event.\r\n\r\nFlorida imposes criminal penalties for structuring specific to money services businesses. Structuring amounts above $300 is a third-degree felony. Structuring amounts above $20,000 is a second-degree felony. Structuring amounts above $100,000 is a first-degree felony. These penalties apply to any person, including employees who assist in structuring." }