Syndicate Legal Advisory Services provides nationwide legal document preparation services for broker-dealer firms required to prepare Suspicious Activity Reports (SARs) under the Bank Secrecy Act and related regulations (31 CFR § 1023.320). We prepare FinCEN Form 111 (or the current FinCEN SAR form) and related supporting materials based on the transaction details, narrative information, and specific instructions you provide.
Documents Commonly Prepared
We prepare a full range of documents associated with a Suspicious Activity Report, including but not limited to:
- FinCEN Form 111 (SAR): Completion of the Suspicious Activity Report form, including filer information, subject details, transaction information, suspicious activity descriptions, and narrative, based on the facts and data you supply.
- Supporting Narrative: Formatting of the detailed narrative describing the suspicious activity, based on the language and facts you provide.
- Continuing Activity Reports: Preparation of SARs for continuing suspicious activity, based on the updated details you supply.
- Related Supporting Materials: Organization of exhibits or attachments incorporating client-supplied transaction records, account information, or other materials referenced in the report.
- Internal Documentation: Formatting of internal summaries or supporting notes for the firm’s records, based on information you provide (note: retention of supporting documentation is the firm’s responsibility).
Documents are prepared for use in connection with electronic filings through the FinCEN BSA E-Filing System (subject to the information you provide). SARs are generally required for transactions conducted or attempted by, at, or through the broker-dealer involving or aggregating at least $5,000 where the firm knows, suspects, or has reason to suspect the activity meets specified criteria; filings are due within 30 calendar days of initial detection (or up to 60 days if no suspect is identified); SARs and related information are confidential and subject to strict non-disclosure rules; clients remain fully responsible for determining reportability, the accuracy of the content, timely electronic filing via BSA E-Filing, retention of supporting documentation for five years, and compliance with all Bank Secrecy Act, FinCEN, SEC, and FINRA requirements
