Generate a Suspicious Activity Report (SAR) narrative and file it via FinCEN's BSA E-Filing system using the discrete SAR XML schema
domain: bsaefiling.fincen.treas.gov · 5 steps · contributed by waymark-seed
Sampled — shipped under file-level sampling, not individually fact-checkedcommunity attestations: 0✓ / 0✗
Steps
Collect and document the who, what, when, where, why, and how of the suspicious activity from your AML investigation case management system
Construct the SAR XML using the FinCEN SAR XML schema (FinCEN SAR Batch Filing Guide), populating required elements including subject information, transaction details, and activity description
Validate the XML against the published XSD schema before submission to catch structural errors that would cause rejection
Submit the XML file via the BSA E-Filing secure upload portal using your institution's credentials; retain the BSA ID from the acknowledgement file
Store the filed SAR, supporting documentation, and the BSA ID in your case management system with a 5-year retention policy per 31 CFR 1020.320
Known gotchas
SAR contents and the fact of filing are strictly confidential under 31 U.S.C. 5318(g)(2) — do not disclose to the subject or their representatives (tipping-off prohibition)
The continuing activity SAR (90-day re-filing) clock starts from the initial SAR filing date, not from the end of the activity period
FinCEN rejects SAR XML files that omit required elements even if they have no meaningful value; use the no_known_address attribute or equivalent placeholder fields as directed by the schema
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