When must I file a SAR for a sanctions violation?

Within 30 calendar days of initial detection. If no suspect is identified, 60 days.

Can I tell the customer I filed a SAR?

No. Tipping off is a federal crime under 31 USC 5318.

Do I file a SAR AND an OFAC blocking report?

They are separate. SAR goes to FinCEN. Blocking report goes to OFAC for SDN matches.

Can AI agents automate SAR filing?

AI can gather data and pre-populate fields, but human review and certification are required.

How to file a SAR for sanctions violations

If you suspect a sanctions violation, you must file a Suspicious Activity Report (SAR) with FinCEN within 30 days.

TL;DR: A sanctions-related SAR is filed when you detect a transaction involving a sanctioned entity, jurisdiction, or evasion pattern. Deadline: 30 days from detection.

Step 1: Identify the suspicious activity

Red flags: transactions involving OFAC-designated addresses or names, payments through sanctioned jurisdictions, structured payments, shell company patterns.

Step 2: Gather supporting documentation

Step 3: File the SAR within 30 days

File via the FinCEN BSA E-Filing System (FinCEN Form 111). The narrative is the most important part.

Step 4: Notify OFAC if blocked transaction

If the transaction involves blocked property (SDN match), also file OFAC blocking report within 10 business days and annual report by September 30.

Information needed	Details
Subject information	Name, address, DOB, ID, wallet address
Transaction details	Amount, date, method, counterparties
Sanctions screening result	OFAC match details, match date

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Frequently Asked Questions

When must I file a SAR for a sanctions violation?: Within 30 calendar days of initial detection. If no suspect is identified, 60 days.
Can I tell the customer I filed a SAR?: No. Tipping off is a federal crime under 31 USC 5318.
Do I file a SAR AND an OFAC blocking report?: They are separate. SAR goes to FinCEN. Blocking report goes to OFAC for SDN matches.
Can AI agents automate SAR filing?: AI can gather data and pre-populate fields, but human review and certification are required.