Filing a SAR within Persona
SARs (Suspicious Activity Reports) can be filed manually as XML exports or automatically through e-filing.
Validating your SAR
After compiling your SAR form and narrative, click Save
, then Validate
. Upon hitting Validate
, you'll notice check marks or alert icons next to each section of the SAR form. Resolve any validation issues and then save and validate again to ensure your SAR is prepared for submission.
Manual Filing
Only users with SAR filing dashboard permissions can initiate SAR exports from the Persona dashboard. Once your SAR form has been validated, your organization can download it as an XML file for upload to the BSA portal. To manually export a SAR, follow these steps:
-
Click on the SAR record ID within the case to navigate to the SAR record
-
Locate
More...
in the top right corner, then selectExport SAR for manual filing
-
Click
Sign and export
which will finalize the export and move it to aFiled
status -
Upon export, manually submit the XML file to FinCEN using the BSA SAR filing website
E-filing from Persona
Only users with SAR filing dashboard permissions can initiate e-filing from the Persona dashboard.
To electronically file a SAR, follow these steps:
- Click on the SAR record ID within the case to navigate to the SAR record
- Locate the
Send to FinCEN
button positioned in the top right corner of the page of the SAR record - Click the button to initiate the filing process. A confirmation modal will appear, asking you to confirm your intention to file the SAR with FinCEN
- Press
Sign and submit
to proceed with the submission. A popup message will appear, indicating that the submission is in progress
Upon successful initiation of the SAR transmission, you will notice the status badge at the top of the SAR record update from Open
to Filed
, signifying that the SAR has been submitted
Understanding the SAR e-filing lifecycle
Manual filing status lifecycle
- Open: This status denotes the initial stage of the SAR within Persona.
- Filed: Once the SAR has been manually exported, it enters the Filed status. For manual exports,
Filed
is the terminal status. At this stage, the SAR is locked and cannot be edited directly. To make changes to a locked SAR, you will need toClone
the SAR record.
E-filing status lifecycle
- Open: This status denotes the initial stage of the SAR within Persona.
- Filed: Once the SAR has been electronically filed to FinCEN, it enters the Filed status. At this stage, the SAR is locked and cannot be edited directly. To make changes to a locked SAR, you will need to
Clone
the SAR record.
After submission, the BSA e-Filing system automatically conducts validations. Within approximately an hour, the filing institution receives notification of acceptance or rejection via email. It's important to note that Persona does not directly receive this email from FinCEN; instead, it is sent directly to the financial institution.
- Accepted: This status denotes that the SAR was accepted for processing
- Rejected: This status denotes that there were validation errors on the SAR form that need to be fixed.
- To fix the SAR, click on the
••• More
button to and then clickClone
. This will duplicate all the fields on the SAR record. Fix any issues before e-fling again.
After the SAR form has been accepted and upon completion of processing by FinCEN, the BSA e-Filing system triggers acknowledgment notifications. At this point the accepted SAR will moved to a processed state.
- Processed: Persona updates the filing status along with the BSA ID within the dashboard upon receiving the processed notification from FinCEN. Additionally, an acknowledgment email is sent from the BSA e-Filing system to the filing institution.
Fixing a Rejected SAR
If your SAR file has been rejected by FinCEN, follow these steps:
- Duplicate the SAR file by clicking on the
… More
button to and then clicking onClone.
2. Select “Correct / Amend prior report” under Filing type. You’ll be asked to provided the BSA ID of the original SAR filed. You can find the BSA ID of the SAR previously submitted within the SAR Filing dashboard page. 3. Make sure report is completely filled out and has the corrections. 4. Submit the amended report.