On 31 May, an article from Ballard Spahr reported a Notice from FinCEN Notice that gives the financial industry and affected stakeholders an opportunity to comment on existing regulatory requirements, as well as associated burdens.  It also says that the Notice provides interesting insights and statistics into current SAR reporting.  These include that, in 2019, 54% of SAR came from banks and nearly 33% from MSB – meaning that those from other types of organisation were in percentages in single figures, or even less than 1%.  It seems that FinCEN also revised its methodology of calculating the burden of filing SAR, including the time and effort estimates involved in the determination not to file a SAR.  FinCEN describes 6 stages involved in the filing of a SAR but its cost estimates only try to account for the final 3 stages.


If you would like to say thanks by making a small contribution, in case I need to upgrade or replace my computers and other paraphernalia, I have a page at

Author: raytodd2017

Chartered Legal Executive and former senior manager with Isle of Man Customs and Excise, where I was (amongst other things) Sanctions Officer (for UN/EU sanctions), Export Licensing Officer and Manager of the Legal-Library & Collectorate Support Section

Leave a Reply

Fill in your details below or click an icon to log in: Logo

You are commenting using your account. Log Out /  Change )

Google photo

You are commenting using your Google account. Log Out /  Change )

Twitter picture

You are commenting using your Twitter account. Log Out /  Change )

Facebook photo

You are commenting using your Facebook account. Log Out /  Change )

Connecting to %s