by Debra Eshbaugh, CAMS and Terri Luttrell, CAMS-Audit, Senior Managers of Strategy & Engagement, Banker’s Toolbox 

FinCEN Extends SAR XML Filing Deadline to February 1

If you were not able to take BSA/AML system upgrades required for the January 2, 2019 new SAR XML format, you are in luck!

On December 17th, FinCEN released a notice extending the SAR XML filing deadline from January 2, 2019, to February 1, 2019.

What does that mean for your organization?

Institutions that discreet file their SARs should still be able to choose either discreet format option when logging in to FinCEN’s E-file site through January 31st.  As of February 1, 2019, discreet filers will only have access to the compliant SAR discreet form (v1.2).

Institutions utilizing Banker’s Toolbox software to complete and file SAR Batches that have already installed the new upgrade are unaffected and are fully compliant with the new form requirements. 

Institutions that have not yet installed the compliant SAR format to their production systems prior to yearend will need to ensure compliance by the new deadline. As of February 1, 2019, institutions that have not upgraded will no longer be able to batch file SARs with FinCEN.  

Eshbaugh has over 30 years’ experience in the financial industry. She spent 10 years working extensively within Retail Banking and Consumer Lending before moving to Bank Operations. During her 20 years in operations, she managed several areas including Deposit and Retirement Operations, Item Processing, ATM/Cards, Retail & Commercial Cash Vaults and Armored Transport. She joined Banker’s Toolbox as a Product Manager for the BSA/AML product suite in 2010. In 2018, Debra became a Senior Manager of Strategy and Engagement, providing actionable insights to support long-term company strategy based on analysis of market and industry trends, competitor developments, financial and regulatory technology changes and exploration and evaluation of potential partnerships. Eshbaugh continues to serve as a spokesperson and subject-matter expert in BSA/AML typologies and regulatory requirements as well as product offerings.

Luttrell is a seasoned AML professional with over 20 years in the banking industry, working both in medium and large community and commercial banks ranging from $2 billion to $330 billion in asset size. Terri is currently Senior Manager of Strategy & Engagement at Banker’s Toolbox. Banker’s Toolbox is the leading enterprise risk management solution for financial institutions, offering a suite of products to help mitigate risk and streamline compliance. The Banker’s Toolbox team is a unique combination of seasoned bankers, former regulators, and information technology consultants who specialize in designing, developing, and implementing risk management solutions while providing unparalleled customer service.