How to Complete and File a Suspicious Transaction Report (STR Form)

To file a suspicious transaction report in the United States, you submit a FinCEN Suspicious Activity Report (SAR) electronically through FinCEN’s BSA E-Filing System within 30 calendar days of first detecting the activity, completing all five parts of the form and paying particular attention to the narrative. What many people call a “suspicious transaction report” or “STR” is known in U.S. regulatory practice as the FinCEN SAR under the Bank Secrecy Act; some other countries use the STR label, but the process, thresholds, and penalties below follow U.S. law.

When You Have to File

A SAR is required when a transaction conducted or attempted at your institution involves at least $5,000 in funds and you know, suspect, or have reason to suspect that the transaction is designed to evade BSA reporting requirements, lacks a lawful purpose, or involves funds from illegal activity.¹ The $5,000 floor is separate from the $10,000 currency transaction report threshold. Structuring deposits to stay just under $10,000 is itself a SAR trigger.²

The clock starts on the date you first detect facts that may warrant a filing. You have 30 calendar days from that date. If no suspect has been identified when you first detect the activity, you get an additional 30 days to try to identify one, but the filing cannot be delayed more than 60 calendar days from the detection date under any circumstances.³

Common triggers include activity inconsistent with a customer’s profile, transactions with no apparent economic purpose, false or suspicious identification, and rapid movement of funds in and out of an account. Cyber events aimed at conducting or affecting a transaction of $5,000 or more also require a SAR, and filings on those events should include IP addresses with timestamps, device identifiers, and any indicators of compromise.⁴ For human-trafficking-related activity, reference “HUMAN TRAFFICKING FIN-2020-A008” in the narrative and select the appropriate activity characterization.⁵

One boundary worth stating: receiving a grand jury subpoena or law enforcement inquiry does not by itself require a SAR. Treat the subpoena as relevant information in your risk assessment, review the underlying accounts, and file only if the activity independently meets SAR criteria. If you do file, focus the report on the suspicious facts, not on the subpoena.⁶

Completing the Five Parts of the FinCEN SAR

The FinCEN SAR is divided into five parts, and each collects a different category of information. All five must be completed for the filing to be useful.³

Part I: Subject Information

Complete a separate Part I for every known subject of the suspicious activity. Victims are not subjects and do not belong here. For each subject, provide:

Full legal name (last, first, middle), aliases or “doing business as” names, date of birth, and gender
Street address, city, state, ZIP code, and country
Tax identification number (SSN, ITIN, or EIN) and TIN type
Government-issued identification number, along with the issuing state and country
Relationship to the institution — accountholder, employee, agent, or other — with the status of that relationship and any relevant account numbers
The subject’s role in the suspicious activity

If you genuinely cannot identify anyone, check the box indicating that all critical subject information is unavailable and file anyway. A SAR with an unknown subject is far better than no SAR.

Part II: Suspicious Activity Information

Part II captures the dollar amount, the date or date range, and the type of conduct. Items 29 through 38 present ten broad categories with checkboxes: structuring, terrorist financing, fraud, casino-related activity, money laundering, identification fraud, insurance fraud, securities fraud, mortgage fraud, and other. Check every category that applies. If none fits, check “other” and describe the activity in the text field or narrative. Leaving all boxes blank is a documented filing error. Part II also collects product types, payment mechanisms, and, for cyber-related filings, IP addresses and CUSIP numbers.

Part III: Financial Institution Where the Activity Occurred

Fill out a separate Part III for each institution involved. The section asks for the legal name, TIN, type of institution, primary federal regulator, and role in the transaction. If a specific branch was involved, include its identifying information and address.

Part IV: Filing Institution Contact Information

Part IV identifies the lead entity actually submitting the SAR, which may differ from the institution in Part III when a holding company files for a subsidiary. Only one Part IV record is permitted per filing. Include the contact person’s name, title, and phone number so FinCEN or law enforcement can reach the right person.

Part V: The Narrative

The narrative is the most important section of the SAR and the one filers most often mishandle. FinCEN’s own guidance states that the care taken with the narrative “may determine whether the described activity and its possible criminal nature are clearly understood by investigators.”³

A good narrative answers who, what, when, where, and why the activity appeared suspicious. Write it in chronological order when the activity spans multiple dates. Note whether transactions completed or were only attempted. Explain who benefited financially. Write it in English.

Do not simply repeat data already entered in Parts I through III. Add context and explanation. Reference any supporting documentation you are retaining, but do not attach or upload those documents with the SAR itself. If the filing is a correction or amendment, describe the changes at the beginning of the narrative. For continuing reports, cover only the current review period rather than restating prior narratives in full.

Submitting Through BSA E-Filing

All SARs must be submitted electronically through FinCEN’s BSA E-Filing System. Paper forms have not been accepted since April 2013.⁷ The system supports individual filings as well as batch uploads for high-volume filers.⁸

Before your institution can file, someone has to enroll as the Supervisory User, who serves as liaison between BSA E-Filing and the filing organization.⁹ The Supervisory User then creates accounts for the staff who will prepare and submit reports.

Once you submit a SAR, the system immediately displays a confirmation page with a unique Tracking ID, the date and time of submission, and the submitter’s information. Within 48 hours the status changes from “Accepted” to “Acknowledged,” and FinCEN sends the official BSA ID to the filer’s secure mailbox inside the system.¹⁰ Record that BSA ID. You will need it for any correction, amendment, or continuing report on the same activity.

Corrections, Amendments, and Continuing Reports

File a corrected report when you discover an error in a previously filed SAR. File an amended report when new information surfaces about the same activity but circumstances do not justify a continuing report. In both cases, check box 1b (“Correct/Amend prior report”), enter the prior report’s Document Control Number or BSA ID in field 1e, and complete the entire form again with the necessary changes. Describe the corrections or amendments at the start of the Part V narrative.¹¹ FinCEN recommends making corrections within 30 days of receiving error notifications.

For ongoing suspicious activity, FinCEN previously suggested filing continuing SARs at least every 90 days, with the deadline being 120 calendar days after the date of the previous related SAR. More recent guidance from FinCEN and the federal banking agencies clarifies that institutions are not strictly required to follow that 90-day cycle. They may instead file continuing SARs as appropriate under their own risk-based monitoring programs, provided those programs are reasonably designed to identify and report suspicious activity.¹² In practice, most institutions still work on the 90/120-day framework because examiners expect it.

Never Tell the Subject

Federal law prohibits anyone involved in a SAR from telling the subject that a report has been filed. Under 31 U.S.C. § 5318(g)(2)(A), no director, officer, employee, or agent of a financial institution, current or former, may notify a person involved in the transaction that it has been reported, or reveal any information that would disclose the report’s existence.¹³ The same prohibition applies to government employees who learn about the SAR.

Violating the confidentiality rule carries civil penalties of up to $100,000 per disclosure and criminal penalties of up to $250,000 in fines and five years in prison.¹⁴ In exchange for that secrecy obligation, the statute provides a safe harbor: institutions and their employees that file SARs in good faith are shielded from liability to any person for making the disclosure or for failing to notify the subject.¹³

Keeping the Records

Retain a copy of every SAR you file, along with all supporting documentation, for five years. FinCEN’s filing instructions are explicit: “Describe all supporting documentation and retain the documentation for five years. DO NOT include supporting documentation with the FinCEN SAR.”³ That covers transaction records, account statements, copies of identification documents, internal investigation notes, and anything else that informed the filing decision. These records must be available for inspection by examiners and law enforcement upon request.

Common Filing Errors to Avoid

FinCEN has published guidance identifying the mistakes that most often undermine SARs.¹⁵ The recurring problems are worth checking against your own draft before submission:

An empty or inadequate narrative. This is the most common problem. A narrative that only repeats the fixed-field data does not explain why the activity was suspicious.
Referencing attached documents instead of describing them. Supporting documents cannot be uploaded, so describe the contents rather than writing “see attached.”
Invalid identification numbers. Placeholders like “000000000” or “999999999” distort the database. If a number is genuinely unknown, leave the field blank or check the unavailable box.
An incomplete filer EIN. Entering the EIN with hyphens in a nine-digit field drops the last digit.
A missing filer telephone number. Investigators use it to call directly.
No suspicious activity category selected. Items 29 through 38 should never be entirely blank. If nothing fits, check “other” and explain.

Penalties for Getting It Wrong

Civil penalties scale with the severity of the violation. A willful failure to comply with BSA requirements can bring a civil penalty of up to the greater of the amount involved in the transaction (capped at $100,000) or $25,000 per violation. Negligent violations carry up to $500 per incident, and a pattern of negligent violations can add up to $50,000 more.¹⁶

Criminal exposure is steeper. A willful BSA violation can bring a fine of up to $250,000 and up to five years in prison. If the violation is part of a pattern of illegal activity involving more than $100,000 in a 12-month period, the maximum fine doubles to $500,000 and the prison term extends to 10 years. Individuals convicted must also forfeit any profits gained from the violation and repay any bonuses received during the calendar year of the offense or the year after.¹⁷ FinCEN also brings enforcement actions directly against institutions, and those actions are public.

1
National Credit Union Administration. Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
2
FFIEC BSA/AML InfoBase. FFIEC BSA/AML Assessing Compliance with BSA Regulatory Requirements – Suspicious Activity Reporting
3
Financial Crimes Enforcement Network. FinCEN Suspicious Activity Report Electronic Filing Instructions
4
Financial Crimes Enforcement Network. Advisory to Financial Institutions on Cyber-Events and Cyber-Enabled Crime
5
Financial Crimes Enforcement Network (FinCEN). Supplemental Advisory on Identifying and Reporting Human Trafficking and Related Activity
6
National Credit Union Administration. Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
7
FinCEN. Bank Secrecy Act Filing Information
8
Financial Crimes Enforcement Network. BSA E-Filing System
9
Financial Crimes Enforcement Network. Becoming a Registered E-Filer – BSA E-Filing System
10
Financial Crimes Enforcement Network. Frequently Asked Questions Regarding the FinCEN Suspicious Activity Report (SAR)
11
Financial Crimes Enforcement Network. FinCEN SAR Electronic Filing Requirements
12
Board of Governors of the Federal Reserve System. Frequently Asked Questions Regarding Suspicious Activity Reporting
13
Office of the Law Revision Counsel. 31 USC 5318 – Compliance, Exemptions, and Summons Authority
14
Financial Crimes Enforcement Network. FinCEN Advisory FIN-2010-A014 – Maintaining the Confidentiality of Suspicious Activity Reports
15
Financial Crimes Enforcement Network. Suggestions for Addressing Common Errors Noted in Suspicious Activity Reports
16
Office of the Law Revision Counsel. 31 USC 5321 – Civil Penalties
17
Office of the Law Revision Counsel. 31 USC 5322 – Criminal Penalties