At the top of any SAR form is the statement, ?Always complete entire report.? On some SAR forms,28 this is appended with a statement that items denoted by an asterisk (*) are considered critical.
What constitutes ?completing? a SAR?
A SAR form has been completed when all of the available information has been entered and responses such as ?none? or ?not available? have been entered in any blank critical field. These responses are words, phrases, or codes that inform FinCEN that data for that item is unavailable or not applicable, and has not been simply overlooked by the filer. Items are considered critical when they contain important information required for law enforcement investigations, such as: subject name; subject identifying number and address; type of suspicious activity; and a detailed narrative.
These responses are needed for several reasons. First, they tell law enforcement and data collectors that the filer considered the item. Second, such responses indicate the requested information was not available at the time of filing, did not exist, or did not apply to the suspicious activity. Third, such responses assist in the processing of BSA data by eliminating the need to correspond with the filers to obtain what appears to be missing information.
Responses commonly used in SARs to clarify what appears to be missing data, their definitions, and examples of how they are used:
28SAR-MSB (Form TD F 90-22.56), SAR-SF (FinCEN Form 101), and SAR-C (FinCEN Form 102).
Excerpted from SAR Activity Review Issue 6, page 50