Question: Hi Heather,
Do you have a trick for remembering how to complete the “Selling Location” or “Paying Location” and the suspects role “Purchaser/Sender” or Payee/Receiver” fields on the FinCEN SAR form? I always trip myself up for cash structuring SARs.

Answer:

See Q&A #18 on FinCEN’s SAR FAQs:

18. How do we complete Item 56/68 on the new FinCEN SAR which asks for the financial institution or branch’s “role in transaction,” and provides options for “Selling location,” “Paying Location,” or “Both”?

Items 56 and 68 are non-critical fields, however, and only need to be completed if they are applicable to the activity being reported. As an example, if the activity being reported on the FinCEN SAR involved only the structuring of cash deposits, then a financial institution would not complete Items 56 or 68, as the institution was neither a “paying” nor “selling” location in the activity being reported.

The FAQ’s don’t direct address the Purchaser/Sender or Payee/Receiver fields, but it’s going to be similar. The SAR Filing Instructions indicate that you only complete the Subject’s role in suspicious activity “if applicable.” This field is a non-critical field, and you can leave it blank if the suspect didn’t send or receive funds as part of the transaction.

So, for structured cash withdrawals or deposits, you’d leave all these fields blank.