FinCEN Extends Deadline for Adopting New CTR and SAR

On Dec. 20, 2011, the Financial Crimes Enforcement Network (FinCEN) announced that the deadline for financial institutions to utilize FinCEN’s new Currency Transaction Report (CTR) and Suspicious Activity Report (SAR) for reporting purposes will be extended to March 31, 2013.

FinCEN is extending the deadline partly in response to industry concern about having sufficient time to transition to the new reports, including any necessary changes to their internal processes and/or information technology (IT) systems. FinCEN had proposed that the new reports be implemented by June 30, 2012, the same date proposed for ending the paper filing option for FinCEN forms. FinCEN expects this extended timeframe for incorporating the new CTRs and SARs to ease the industry’s transition to these new reports.

FinCEN will soon make available industry testing arrangements, demonstration reports, and other helpful technical information for the new CTRs and SARs and will subsequently announce when the new reports will be made available for filing purposes.

FinCEN will continue to accept submissions to its Bank Secrecy Act (BSA) E-Filing System that use the most current “legacy” forms (such as the CTR, CTRs by casinos, and industry-specific SARs) until the mandated use of the new reports in 2013.

For those financial institutions unable to meet the proposed electronic filing deadline, FinCEN will consider, based on certain limited hardship exceptions, specific requests to file the most current paper forms for up to one year past the mandatory electronic filing deadline. Further information on how financial institutions can make such requests will be provided in a future notice.


Questions? Contact the Compliance Hotline: 1.800.546.4465,

Posted in Compliance News.