District Circular Letters

October 3, 2001

BANKING SUPERVISION AND REGULATION:
SUSPICIOUS FINANCIAL TRANSACTIONS

To State Member Banks, Bank
Holding Companies, U.S. Branches
and Agencies of Foreign Banks,
and Others Concerned,
in the Twelfth Federal Reserve District

Reporting Suspicious Transactions Relating to the Recent Terrorist Attacks to Law Enforcement

Banking organizations supervised by the Federal Reserve and the other federal financial institutions supervisory agencies are required to report known or suspected criminal law violations relating to the recent terrorist attacks to law enforcement authorities by filing Suspicious Activity Reports (SARs) as expeditiously as possible. On September 18, 2001, the Board issued SR letter 01-22 that includes the FBI's public list of suspects in the attacks and advises banking organizations to contact specified FBI agents working on the investigation by telephone or by faxing SARs to the FBI. The FBI’s fax number is (202) 278-2598. (Please see our letter dated September 19, 2001.)

FinCEN Establishes Toll-Free Number to Report Suspicious Activities

On September 26, 2001, the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) established a new toll-free hotline that banking organizations can call to report suspicious activities related to the terrorist attacks. The hotline number is 1(866) 556-3974. It was established to provide financial institutions with an additional mechanism to immediately inform law enforcement about suspicious activities related to terrorism, and will be operational 24 hours a day, seven days a week.

Banking Organizations Must Report Suspicious Activity on a SAR Form

Banking organizations are still required to file SARs in accordance with the banking agencies' suspicious activity reporting rules, but they may choose to directly contact a local office of the FBI or other law enforcement authority in addition to or instead of calling the new FinCEN hotline.

When filing SARs, banks and other financial institutions should take care in ensuring that all pertinent information about the suspicious activities are reported, including any account information. The Federal Reserve also asks that all banking organizations reporting information about the recent terrorist attacks in their SARs check the "Other" box on line 35(s) of the SAR form (summary characterization of suspicious activity information) and include the term "Terrorism" in the space provided. This will ensure that law enforcement authorities give immediate attention to a SAR reporting suspicious activity related to the recent attacks.

Additional Information

All circulars and documents are available on the Internet through the Federal Reserve Bank of San Francisco's Internet site, at http://www.frbsf.org/banking/letters.

Questions concerning SAR reporting can be directed to Herbert A. Biern, Senior Associate Director, at (202) 452-2620, Carmina Hughes, Special Counsel, at (202) 452-5235, or Pamela J. Johnson, Senior Anti-Money Laundering Coordinator, at (202) 728-5829.

FEDERAL RESERVE BANK OF SAN FRANCISCO