Select the roles (“FinCEN CTR Filer,” “FinCEN CTR Batch Filer,” “FinCEN SAR Filer,” “FinCEN SAR Batch Filer,” “FinCEN DOEP Filer,” “FinCEN DOEP Batch Filer,” etc.) in the “Remaining Roles” box that need to be added for the general user.Ģ.
Upon reaching the next webpage, the supervisory user must:ġ. Select the general user whose access roles require updating. Select “Manage Users” from the left-hand side under “User Management.”ģ. The supervisory user must grant access for the general users to be able to view the new FinCEN reports.Ģ. Supervisory users of the BSA E-Filing System are able to view all available FinCEN reports when they log into the BSA E-Filing System. If you cannot view or access the new FinCEN CTR, please contact your supervisory user to request access. “General users” of the Bank Secrecy Act (BSA) E-Filing System can only view those reports that the “supervisory user” has given them permission to see. If your institution has questions regarding the applicability of this general guidance, please contact the FinCEN Regulatory Helpline at (800) 949-2732 for further information.
ABC BOX COMPANY PAYROLL DIRECT DEPOSIT SOFTWARE
Such software updates should be implemented within a reasonable period of time. If a filing has been submitted in which such information was not included because of such a limitation in the filing software, an amended filing should be completed using either the discrete filing method or an amended batch filing, once the software is updated.
In general, if your financial institution’s filing software does not permit the institution to include information in a field without an asterisk where information has been collected and is pertinent to the report, the financial institution should instead complete a discrete filing for those transactions until the software is updated. Therefore, a financial institution may leave non-critical fields without an asterisk blank when information is not readily available.įinCEN expects financial institutions to have the capability to submit information for any of the data fields in the FinCEN CTR or SAR (or any other FinCEN report). However, the new FinCEN SAR and FinCEN CTR do not create any new obligations to collect data, either manually or through an enterprise-wide IT management system, where such collection is not already required by current statutes and regulations, especially when such collection would be in conflict with the financial institution’s obligations under any other applicable law.
Based upon feedback from law enforcement officials, such information is important for query purposes. As explained in FinCEN’s March 2012 guidance ( FIN-2012-G002 ), for both critical and non-critical elements, financial institutions should complete those Items for which they have relevant information, regardless of whether or not the individual Items are deemed critical for technical filing purposes.įor critical Items, financial institutions must either provide the requested information or affirmatively check the “Unknown” (Unk.) box that is provided on the FinCEN CTR and FinCEN Suspicious Activity Report (SAR) (or any other FinCEN Report).įor non-critical Items, FinCEN expects financial institutions will provide the most complete filing information available within each report consistent with existing regulatory expectations.
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