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l l★K Federal Reserve Bank of Dallas October 15, 2001 DALLAS, TEXAS 75265-5906 Notice 01-78 TO: The Chief Executive Officer of each financial institution and others concerned in the Eleventh Federal Reserve District SUBJECT Reporting Suspicious Transactions Relating to the Recent Terrorist Attacks DETAILS On September 26, 2001, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) established a new toll-free hot line that banking organizations can call to report suspicious activities related to the terrorist attacks. The hot line number is (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. As described by FinCEN in the attached statement, banking organizations are still required to file Suspicious Activity Reports in accordance with the banking agencies’ suspicious activity reporting rules, and 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 hot line. ATTACHMENTS Copies of the Board’s SR letter and the Treasury’s pronouncement are attached. MORE INFORMATION For additional information, please contact Tim Yarbrough, Banking Supervision Department, (214) 922-6217. For additional copies of this Bank’s notice, contact the Public Affairs Department at (214) 922-5254 or access District Notices on our web site at http://www.dallasfed.org/banking/notices/index.html. For additional copies, bankers and others are encouraged to use one of the following toll-free numbers in contacting the Federal Reserve Bank of Dallas: Dallas Office (800) 333-4460; El Paso Branch Intrastate (800) 592-1631, Interstate (800) 351-1012; Houston Branch Intrastate (800) 392-4162, Interstate (800) 221-0363; San Antonio Branch Intrastate (800) 292-5810. BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D. C. 20551 DIVISION OF BANKING SUPERVISION AND REGULATION SR 01-23 (ENF) September 28, 2001 TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK AND TO EACH DOMESTIC AND FOREIGN BANKING ORGANIZATION SUPERVISED BY THE FEDERAL RESERVE SUBJECT: 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 information concerning 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 distributing the FBI's public list of suspects of its investigation of the attacks and advising banking organizations that they could contact specified FBI agents working on the investigation by telephone or by sending their SARs through facsimile to the FBI.1 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. A copy of the FinCEN pronouncement is attached. As described by FinCEN in the attached statement, banking organizations are still required to file SARs in accordance with the banking agencies' suspicious activity reporting rules, and 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 of the SAR form (summary characterization of suspicious activity information) and include the term "Terrorism" in the space provided. This will assure that law enforcement authorities give immediate attention to a SAR reporting suspicious activity related to the recent attacks. 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. The Reserve Banks are requested to distribute this SR letter and FinCEN's September 26 pronouncement to each domestic and foreign banking organization supervised by the Federal Reserve promptly. Richard Spillenkothen Director Attachment Notes: 1. The FBI’s facsimile number is (202) 278-2598. Treasury Establishes FINANCIAL INSTITUTIONS HOTLINE Relating to Terrorist Activity The Treasury Department’s Financial Crimes Enforcement Network (FinCEN) has established a FINANCIAL INSTITUTIONS HOTLINE, 1-866-556-3974, for financial institutions to voluntarily report to law enforcement suspicious transactions that may relate to recent terrorist activity against the United States. The purpose of the HOTLINE is to facilitate the immediate transmittal of this information to law enforcement and it will be operational 7 days a week, 24 hours a day. Information pertaining to the Office of Foreign Assets Control’s (OFAC) Specially Designated Nationals List, or questions concerning the financial institution’s compliance with OFAC regulations, should be directed to OFAC at its existing hotline at 1-800-540-6322. Financial institutions identifying suspicious transactions under 31 CFR Part 103 or under the regulations of their federal financial institution regulators are required to report such transactions by filing a Suspicious Activity Report (SAR) in accordance with applicable agency regulations, even if they provide information over the FINANCIAL INSTITUTIONS HOTLINE. Institutions should file the SAR with the IRS Detroit Computing Center as soon as possible. This HOTLINE is intended to provide to law enforcement and other authorized recipients of SAR information the essence of the suspicious activity in an expedited fashion. The HOTLINE use is voluntary and does not negate an institution's responsibility to file a SAR in accordance with applicable regulations. Financial institutions identifying such suspicious financial activity on a SAR can assist law enforcement by (i) capturing the information on the SAR accurately and completely; (ii) explaining the suspicious transaction as completely as possible in the narrative section; and (iii) including the following information if applicable – any correspondent bank name/account information; names/locations of business entities; names of cities, countries and foreign financial institutions linked to the transaction, especially if wire transfer activity is involved; and account numbers and beneficiary names. In addition, institutions preparing SARs are asked to check the “Other” box on Part III, Line 35(s) of the SAR form and to type in “terrorism” immediately following the box. Nothing in this announcement precludes a financial institution from directly contacting law enforcement or the institution’s federal regulator concerning these issues. 9/26/01
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