Short answer
Banks, money services businesses, casinos, broker-dealers, and other Bank Secrecy Act financial institutions file suspicious activity reports. For a money services business, a SAR is required when a transaction of $2,000 or more conducted or attempted by, at, or through the business is known or suspected to be suspicious. The report is FinCEN Form 111, filed through BSA E-Filing within 30 days of detection, and its existence cannot be disclosed to the customer.
The SAR obligation attaches to regulated financial-institution status, not to company size. For money services businesses the rule is 31 CFR 1022.320: the $2,000 threshold applies to transactions conducted or attempted by, at, or through the MSB, with a $5,000 threshold for issuers of money orders or traveler's checks reviewing their own clearance records. The deadline is 30 calendar days from detection, extendable to 60 when no suspect is identified, and SAR confidentiality is strict: telling the customer a SAR was filed is itself a violation.
For a licensed money transmitter, SAR discipline is tested from two directions: FinCEN owns the rule, and state examiners review the transaction monitoring program that generates the filings during routine exams. Weak suspicious activity reporting is one of the most common examination findings, which is why the designated compliance officer role at /money-transmitter-compliance-officer matters. The full FinCEN filing set for MSBs, including SARs, CTRs, and Form 8300, is mapped at /fincen-compliance-filings.
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