Suspicious Activity Report
Instructions
Safe Harbor Federal law (31 U.S.C. 5318(g)(3)) provides complete protection from civil liability for all reports of suspicious
transactions made to appropriate authorities, including supporting documentation, regardless of whether such reports are
filed pursuant to this report’s instructions or are filed on a voluntary basis. Specifically, the law provides that a financial
institution, and its directors, officers, employees and agents, that make a disclosure of any possible violation of law or
regulation, including in connection with the preparation of suspicious activity reports, “shall not be liable to any person
under any law or regulation of the United States, any constitution, law, or regulation of any State or political subdivision of
any State, or under any contract or other legally enforceable agreement (including any arbitration agreement), for such
disclosure or for any failure to provide notice of such disclosure to the person who is the subject of such disclosure or any
other person identified in the disclosure”.
Notification Prohibited Federal law (31 U.S.C. 5318(g)(2)) requires that a financial institution, and its directors, officers,
employees and agents who, voluntarily or by means of a suspicious activity report, report suspected or known criminal
violations or suspicious activities may not notify any person involved in the transaction that the transaction has been reported.
In situations involving violations requiring immediate attention, such as when a reportable violation is ongoing, the
financial institution shall immediately notify, by telephone, appropriate law enforcement and financial institution
supervisory authorities in addition to filing a timely suspicious activity report.
WHEN TO MAKE A REPORT:
1. All financial institutions operating in the United States, including insured banks, savings associations, savings
association service corporations, credit unions, bank holding companies, nonbank subsidiaries of bank holding
companies, Edge and Agreement corporations, and U.S. branches and agencies of foreign banks, are re-
quired to make this report following the discovery of:
a. Insider abuse involving any amount. Whenever the financial institution detects any known or suspected
Federal criminal violation, or pattern of criminal violations, committed or attempted against the financial
institution or involving a transaction or transactions conducted through the financial institution, where the
financial institution believes that it was either an actual or potential victim of a criminal violation, or series of
criminal violations, or that the financial institution was used to facilitate a criminal transaction, and the
financial institution has a substantial basis for identifying one of its directors, officers, employees, agents or
other institution-affiliated parties as having committed or aided in the commission of a criminal act regardless
of the amount involved in the violation.
b. Violations aggregating $5,000 or more where a suspect can be identified. Whenever the financial
institution detects any known or suspected Federal criminal violation, or pattern of criminal violations, com-
mitted or attempted against the financial institution or involving a transaction or transactions conducted
through the financial institution and involving or aggregating $5,000 or more in funds or other assets, where
the financial institution believes that it was either an actual or potential victim of a criminal violation, or series
of criminal violations, or that the financial institution was used to facilitate a criminal transaction, and the
financial institution has a substantial basis for identifying a possible suspect or group of suspects. If it is
determined prior to filing this report that the identified suspect or group of suspects has used an “alias,” then
information regarding the true identity of the suspect or group of suspects, as well as alias identifiers, such
as drivers’ licenses or social security numbers, addresses and telephone numbers, must be reported.
c. Violations aggregating $25,000 or more regardless of a potential suspect. Whenever the financial
institution detects any known or suspected Federal criminal violation, or pattern of criminal violations, com-
mitted or attempted against the financial institution or involving a transaction or transactions conducted
through the financial institution and involving or aggregating $25,000 or more in funds or other assets, where
the financial institution believes that it was either an actual or potential victim of a criminal violation, or series
of criminal violations, or that the financial institution was used to facilitate a criminal transaction, even though
there is no substantial basis for identifying a possible suspect or group of suspects.
d. Transactions aggregating $5,000 or more that involve potential money laundering or violations of the
Bank Secrecy Act. Any transaction (which for purposes of this subsection means a deposit, withdrawal,
transfer between accounts, exchange of currency, loan, extension of credit, purchase or sale of any stock,
bond, certificate of deposit, or other monetary instrument or investment security, or any other payment, transfer,
or delivery by, through, or to a financial institution, by whatever means effected) conducted or attempted by, at