Number of SARs 16000140001200010000

8000600040002000

02012 2013 2014 2015 2016

44%Increasein 2016 In 2016, the number of financial institutions that filed

at least one SAR indicating they had utilized the 314(b) process in the narrative increased by 37 percent from 2015.

398487

2012 2013 2014 2015 2016

726

997

562

Number of Financial Institutions

37%Increasein 2016

Increased Prevalence of 314(b) References in SAR NarrativesThe number of SARs wherein the utilization of the314(b) Program was discussed in the narrative have increased steadily over the past five years. Calendar year 2016 saw an increase of 44 percent over calendar year 2015.

314(b) References in Suspicious Activity Reports (SARs) Suggest Increased Information Sharing Among Financial Institutions

Number of Financial Institutions Filing SARs Referencing 314(b)

“During a five-year review period, the prevalence of terrorist financing SARs referencing 314(b) has increased significantly, from 25 such SARs in 2012, to 96 such SARs in 2016.”

Number of SARs Indicating Terrorist Financing as the Suspicious Activity Type

25 30

2012 2013 2014 2015 2016

67

96

40

0

20

40

60

80

100

Terrorist Financing SARs Referencing 314(b) Are IncreasingDuring a five-year review period, the prevalence of terrorist financing SARs referencing 314(b) has increased significantly, from 25 such SARs in 2012, to 96 such SARs in 2016. This indicates financial institutions are using 314(b) more frequently in their efforts to detect and report suspected terrorist financing.

25SARs in 2012to 96SARs in 2016

FinCEN Resource Center Insights

U. S. Department of the Treasury . Financial Crimes Enforcement Network . Liaison Division . FinCEN Resource Center

Suspicious Activity Types Reported in SARsMost SARs reporting the use of the 314(b) Program in the narrative indicate money laundering as the suspicious activity category, with “suspicion concerning the source of funds” as the most frequently indicated sub-category1. A review of SAR reporting indicates that financial institutions often use the 314(b) Program to gain clarity from other 314(b) participants on the source of funds moving through their financial institutions. In most of these SARs, the filing institution has contacted another institution through the 314(b) mechanism for additional information on one or more transactions.

“A review of SAR reporting indicates that financial institutions often use the 314(b) Program to gain clarity from other 314(b) participants on the source of funds moving through their financial institutions.”

Types of Financial Institutions

78

2

163

34

38

396232217

23966210

0 1000 2000 3000 4000 5000 6000 7000

Futures Commission Merchants

Mortgage Companies

Mutual Funds

MSBs

Precious Metals, Jewelsand Stones Dealers

Trust Companies

Insurance Companies

Casinos

Broker-Dealers

Depository Institutions

Financial Institution Types Participating in 314(b) Information SharingMany different types of financial institutions participate in the 314(b) Program. These include depository institutions, broker-dealers, casinos, insurance companies, money services businesses (MSBs), futures commission merchants, mortgage companies, mutual funds, precious metals, jewels, and stones dealers, and trust companies. Depository institutions and broker-dealers make up the bulk of 314(b) participants, but several financial institution types, specifically casinos and insurance companies, saw dramatic increases in participation during 2016.

“Depository institutions and broker-dealers make up the bulk of participants, but several financial institution types, specifically casinos and insurance companies, saw dramatic increases in participation during 2016.”

Suspicious Activity Sub-category in Money Laundering SARs (2016)

0% 10% 20% 30% 40% 50% 60% 70% 80% 90%

Suspicious EFT/Wire Transfers

Transaction out ofPattern for Customer(s)

Suspicious use of Noncash Monetary Instruments

Suspicious use of Multiple Accounts

Suspicious Concerningthe Source of Funds

All Others

6%

11%

12%

12%

22%

37%

1The sub-category is officially referred to as the “suspicious activity type” on the SAR form.

U. S. Department of the Treasury . Financial Crimes Enforcement Network . Liaison Division . FinCEN Resource Center