What person/department initiates an SAR? Can a private citizen file one, or does it have to be a government agency?
Primarily banks and other financial institutions, when large amounts of cash are deposited or transferred, greater than $3,000, gt $10,000, etc.
Suspicious Activity Reports (SAR)
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As of April 1, 2013, financial institutions must use the Bank Secrecy Act BSA E-Filing System in order to submit Suspicious Activity Reports.
A financial institution is required to file a suspicious activity report no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing a suspicious activity report. If no suspect was identified on the date of detection of the incident requiring the filing, a financial institution may delay filing a suspicious activity report for an additional 30 calendar days to identify a suspect. In no case shall reporting be delayed more than 60 calendar days after the date of initial detection of a reportable transaction.
Under the Bank Secrecy Act (BSA), financial institutions are required to assist U.S. government agencies in detecting and preventing money laundering, and:
Keep records of cash purchases of negotiable instruments; File reports of cash transactions exceeding $10,000 (daily aggregate amount); and Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion). An amendment to the BSA incorporates provisions of the USA Patriot Act, which requires every bank to adopt a customer identification program as part of its BSA compliance program.
Visit the FinanciaLearn More
l Crimes Enforcement Network (FinCEN).
Read the OCC's implementing regulations at 12 CFR 21.11 and 12 CFR 21.21.
Re Suspicious Activity Reports:
Financial institutions.
https://legal.thomsonreuters.com/en/insights/articles/what-is-a-suspicious-activity-report