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GAO FinCEN needs to further develop form revision
WASHINGTON (4/1/09)--The Financial Crimes Enforcement Network (FinCEN) needs to further develop and document its form revision process, according to a Government Accountability Office (GAO) report released this week. Last year, FinCEN developed a new process for revising Bank Secrecy Act forms, including Suspicious Activity Reports (SARs). The revisions to the SAR form were intended to reduce the number of duplicate reports filed for a single suspicious transaction. The revised form would have provided necessary data blocks and instructions for completing a jointly filed SAR, although accompanying instructions limit joint filing to those suspicious activities that do not involve insider abuse (News Now April 27, 2007). However, implementation of the 2006 revision of the SAR form was delayed due to information technology limitations. In 2008, FinCEN developed a new process for revising BSA forms, including the SAR form. GAO said the limited documentation on the revised process does not provide details to determine how it will incorporate GAO best practices for enhancing and sustaining federal agency collaboration. The process also does not specify roles and responsibilities for stakeholders or depict monitoring, evaluating and reporting mechanisms. According to the report, "FinCEN could achieve some potential benefits--such as greater consensus from all stakeholders on proposed SAR revisions--by incorporating some of the key collaboration practices suggested by the GAO."

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