What is the SAR filing deadline?

30 calendar days from detection of suspicious activity. 60 days if no suspect identified.

When does the SAR clock start?

When the institution detects the suspicious activity, even if no human has reviewed it yet. Automated detection starts the clock.

Do I file a SAR AND a blocking report?

They are separate. SAR goes to FinCEN. Blocking report goes to OFAC for blocked property. File both if applicable.

What if suspicious activity continues?

File continuing activity SARs every 90 days until the activity stops.

SAR filing deadline for sanctions violations

When you detect suspicious activity potentially related to sanctions violations, you must file a SAR with FinCEN within 30 calendar days.

The deadlines

Scenario	Deadline
Suspect identified	30 calendar days from detection
No suspect identified	60 calendar days from detection
Continuing activity (subject already reported)	Every 90 days until activity stops

Start the clock: The deadline starts when the institution detects the suspicious activity, not when a person reviews it. Automated detection starts the clock immediately.

SAR vs. OFAC blocking report

These are separate filings. A SAR goes to FinCEN for suspicious activity reporting. An OFAC blocking report goes to OFAC for blocked property. If you block a transaction AND it is suspicious, file both.

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Frequently Asked Questions

What is the SAR filing deadline?: 30 calendar days from detection of suspicious activity. 60 days if no suspect identified.
When does the SAR clock start?: When the institution detects the suspicious activity, even if no human has reviewed it yet. Automated detection starts the clock.
Do I file a SAR AND a blocking report?: They are separate. SAR goes to FinCEN. Blocking report goes to OFAC for blocked property. File both if applicable.
What if suspicious activity continues?: File continuing activity SARs every 90 days until the activity stops.