What Does FinCEN Recommend for SAR Filing? Unraveling the Implications of AMLA Changes

The ever-evolving landscape of Anti-Money Laundering (AML) regulations took a significant turn with the enactment of the Anti-Money Laundering Act of 2020 (AMLA). Among its various provisions, AMLA mandates the Financial Crimes Enforcement Network (FinCEN) to conduct a comprehensive review of the Suspicious Activity Reports (SARs) process. This review aims to streamline the SAR filing system, evaluate existing thresholds, and explore the feasibility of further automation. In this blog post, we delve into the potential implications of this provision and what FinCEN might recommend for SAR filing.

The AMLA Mandate: An Overview

The SAR filing process has long been a crucial aspect of the AML framework, serving as a means for financial institutions to report suspicious transactions that may indicate money laundering or other illicit activities. AMLA’s mandate for FinCEN to review and potentially enhance this process reflects a recognition of the need for modernization and efficiency in combating financial crimes.

The Implications of AMLA Changes

While the specific recommendations from FinCEN regarding SAR filing are yet to be unveiled, the implications of this provision are significant. The review opens the door to potential changes in the following areas:

  1. Thresholds and Criteria: FinCEN may reconsider existing SAR filing thresholds and criteria, adjusting them to better align with the evolving nature of financial crimes. This could involve reevaluating the dollar amount or transaction characteristics that trigger a SAR filing.
  2. Automation Possibilities: A key aspect of the review involves exploring opportunities for further automation of the SAR filing process. Automation can enhance the efficiency of identifying and reporting suspicious activities while reducing the burden on financial institutions.
  3. Enhanced Collaboration: The SAR filing review may encourage greater collaboration between financial institutions and regulatory bodies. This could involve the sharing of best practices, insights, and intelligence to strengthen the overall AML framework.

The Current Landscape: No Public Pronouncements

As of now, there has been no public movement or pronouncements from FinCEN regarding the SAR filing review mandated by AMLA. The lack of updates adds an element of uncertainty for financial institutions, making it challenging to anticipate the specific changes that may be recommended.

Anticipating FinCEN’s Recommendations

While we await official guidance from FinCEN, it’s essential for financial institutions to stay proactive and prepared. Potential recommendations could focus on leveraging technology for more efficient SAR filing, refining criteria for reporting, and fostering a collaborative environment to combat financial crimes effectively.

Conclusion: Navigating the Future of SAR Filing

As FinCEN undertakes the mandated review of the SAR filing process, financial institutions find themselves at a critical juncture. The potential recommendations could reshape how suspicious activities are identified, reported, and managed. Staying informed, maintaining flexibility in compliance processes, and considering technological solutions will be key to navigating the evolving landscape of SAR filing requirements.

In the midst of these changes, financial institutions can benefit from solutions that offer adaptability and efficiency in compliance. If you are interested in learning more about the PayLynxs advanced SAR workflow, book a complimentary demo here.

What Does Risk-Based AML Monitoring Look Like?

In the ever-evolving landscape of financial crimes, the cost of illicit activities has surged to unprecedented levels, prompting a crucial reevaluation of Anti-Money Laundering (AML) regulations. The Anti-Money Laundering Act of 2020 (AMLA) stands out as a pivotal response, signaling a significant shift towards a risk-based approach to AML monitoring. In this blog post, we’ll explore what risk-based AML monitoring entails and why it’s becoming increasingly essential in the fight against financial crimes.

Understanding the Need for Change

The traditional check-the-box AML compliance approach has proven insufficient in the face of sophisticated and rapidly evolving financial crimes. The surge in financial crime costs, reaching $274.1 billion in 2022, underscores the urgency for a more effective and risk-focused strategy.

Embracing a Risk-Based Approach to AML Monitoring

Risk-based AML monitoring represents a paradigm shift from a one-size-fits-all compliance model to a more nuanced and targeted strategy. Rather than applying uniform measures to all transactions, this approach involves identifying and prioritizing risks based on factors such as customer profiles, transaction patterns, and geographic locations.

Key Components of Risk-Based AML Monitoring

  1. Customer Risk Assessment: Evaluate the risk associated with each customer by considering factors like their business type, location, and transaction history.
  2. Transaction Monitoring: Implement advanced analytics to detect unusual patterns or deviations from established norms in transactional behavior.
  3. Enhanced Due Diligence (EDD): Apply additional scrutiny to high-risk customers, ensuring a more thorough understanding of their activities and associated risks.
  4. Real-Time Alerts: Leverage technology to generate real-time alerts for potentially suspicious activities, enabling swift and proactive responses.
  5. Continuous Monitoring: Establish ongoing surveillance mechanisms to adapt to evolving risks and ensure compliance remains effective over time.

The Challenge: Lack of Guidance

While the intent of AMLA is clear, the lack of implementation guidance from FinCEN has left financial institutions in a challenging position. The absence of clear directives creates uncertainty and impedes the seamless transition to a risk-based AML monitoring framework.

SimpliRisk by PayLynxs

In response to the need for a comprehensive and user-friendly solution, PayLynxs developed SimpliRisk—a cost-effective BSA/AML compliance platform designed to simplify the complexities of risk-based AML monitoring. With customizable, intelligent rules, SimpliRisk allows financial institutions to initiate the transition immediately and tailor it uniquely to their business needs.

As the financial industry adapts to the demands of AMLA and strives for more effective compliance, the role of risk-based AML monitoring becomes increasingly pivotal. With SimpliRisk, PayLynxs offers a solution that not only aligns with the evolving regulatory landscape but also provides a user-friendly and cost-effective platform to fortify your institution against financial crimes. Take the leap into the future of compliance with SimpliRisk today by booking a complimentary demo.

Protecting Your Account Holders: 3 Holiday Scams to Plan For

Criminals ramp up their efforts to take advantage of individuals and their financial institutions during the holidays.  By knowing what to look for, you can use SimpliRisk to help you detect these scams.  In this blog post, we will explore some of the common holiday scams and provide suggestions for how to use SimpliRisk to aid you in detecting them.

Common Holiday Scams

  • Phishing Attacks – Scammers send fraudulent emails or messages designed to trick recipients into revealing personal information, login credentials, and to send money from their account.
  • Account Takeover Fraud – Criminals often attempt to take control of customers’ bank accounts during the holiday season after successful Phishing attacks.
  • Elder Abuse – Romance Scams and Tech Support Scams target elderly individuals to perform transactions or provide accounts access directly or from screen share / screen control sessions.

SimpliRisk Guidance

Many of these scams result in Authorized Push Payment (APP) scenarios, which is very hard to prevent, but can be detected with some of the following configurations within SimpliRisk.

  • Out of Pattern transactions can detect APP scenarios. Using SimpliRisk monitoring series 900 or 5400 you can detect this type of behavior.
  • Elder abuse monitoring will look at multiple types of transactions to identify unusual behavior, given historical trends. Using SimpliRisk monitoring series 5200 you can detect this type of behavior.
  • If there are particular names of entities, processors, or people that you see during the holidays associated with fraud, then use SimpliRisk monitoring series 6600 to help you detect any other transactions with this same information.


Banks and credit unions are at the front lines in the battle against holiday scams, as they often bear the responsibility of safeguarding their customers’ financial well-being. By staying vigilant and proactive, banks can significantly reduce the risk of financial losses and ensure their customers have a safe and secure holiday season. Education, advanced security measures, and effective communication with customers are key in this endeavor. Together, banks and their customers can enjoy the holiday season with peace of mind.

If you would like a consultative session to review the guidance provided in this blog, please reach out to schedule a session with our support team.

The Power of Automation: Why Money Services Businesses Should Automate Their CTR Operations

Money Services Businesses (MSBs) play a crucial role in the financial ecosystem by providing essential financial services, including money transfers, currency exchange, and check cashing. However, operating in this highly regulated industry comes with its own set of challenges, one of which is complying with reporting requirements such as Currency Transaction Reports (CTRs). These reports are mandated by financial regulators to combat money laundering and other financial crimes. While CTRs are vital, they can be incredibly time-consuming and complex to manage manually. In this blog post, we’ll explore why MSBs should consider automating their CTR operations.

  1. Compliance Efficiency
    One of the most compelling reasons for automating CTR operations is the increased efficiency in compliance management. CTRs involve tracking and reporting cash transactions exceeding a certain threshold, typically $10,000, which means MSBs must monitor and document numerous transactions daily. Automation streamlines this process, reducing the risk of human error and ensuring that no significant transactions slip through the cracks.
  2. Accuracy and Error Reduction
    Manual CTR reporting is prone to errors, which can have serious consequences for MSBs. Filing incorrect reports or missing transactions can lead to regulatory fines and penalties. Automation software can significantly reduce the likelihood of such errors, ensuring that CTRs are filed accurately and on time, thereby helping MSBs maintain their regulatory compliance and reputation.
  3. Time and Resource Savings
    Manually preparing and filing CTRs is a time-consuming task. MSB employees spend hours sifting through transaction data, filling out forms, and cross-referencing information. By automating this process, businesses can reallocate their workforce to more value-added tasks and reduce labor costs. This not only saves time but also improves employee morale by minimizing tedious, repetitive work.
  4. Scalability
    As MSBs grow and handle larger volumes of transactions, managing CTRs manually becomes increasingly burdensome. Automation solutions can scale seamlessly to accommodate increasing transaction volumes without a corresponding increase in labor costs. This scalability is essential for businesses looking to expand their operations while maintaining compliance.
  5. Risk Mitigation
    Non-compliance with CTR reporting requirements can result in severe consequences, including regulatory fines, legal actions, and damage to the MSB’s reputation. Automating CTR operations helps mitigate these risks by ensuring that all transactions are accurately reported, deadlines are met, and compliance standards are consistently upheld.
  6. Enhanced Security
    Automation tools often come with advanced security features that protect sensitive transaction data. This is especially important in an industry where data security and confidentiality are paramount. Automating CTR operations can safeguard transaction information from unauthorized access and potential breaches, reducing the risk of data leaks.
  7. Improved Data Analytics
    Automated CTR systems can provide MSBs with valuable insights into their transaction data. By analyzing this information, businesses can identify trends, detect suspicious activities, and make data-driven decisions to optimize their operations and improve risk management.

In today’s regulatory landscape, compliance is not optional for Money Service Businesses; it’s a necessity. Automating Currency Transaction Report operations offers numerous advantages, including enhanced compliance efficiency, reduced errors, time and resource savings, scalability, risk mitigation, improved security, and valuable data analytics. By embracing automation, MSBs can streamline their compliance processes, ensuring they meet regulatory requirements while freeing up resources to focus on growing their businesses and providing better customer service. In an industry where compliance is king, automation is the key to success.