FinCEN Expands E-Filing System Financial Institutions begin filing BSA reports over Secure Internet

The Financial Crimes Enforcement Network (FinCEN) announced today that it hasofficially launched the Patriot Act Communications System (PACS). PACS is designedto allow participating financial institutions to quickly and securely file Bank Secrecy Act(BSA) reports over the Internet. Phase one of the system will allow for the filing of thebank Suspicious Activity Report (Form TD F 90-22.47 or “SAR”) and the CurrencyTransaction Report (Form 4789 or “CTR”).The electronic filing of BSA reports will expedite the reporting process and, thus, makethe information available to law enforcement more rapidly. It is also designed to reduce afinancial institution’s costs in complying with the filing of BSA reports. More than 13million BSA reports are filed with FinCEN each year through the IRS Detroit ComputingCenter, which processes the reports for FinCEN. Prior to the development of PACS,financial institutions could file their reports either on magnetic tape or on paper.Financial institutions are not mandated to use PACS, however the system provides a thirdoption -- electronic filing.Financial institutions wishing to participate in PACS will be able to access the systemonly after their specially designated personnel have applied for and received a digitalcertificate from a Government-approved certificate authority. Information regardingPACS and how to apply to be a user can be found on the FinCEN website at www.fincen.gov.“The deployment of PACS is a win-win for financial institutions and government,” saidJames F. Sloan, Director of FinCEN. “Financial institutions will realize cost savingsthrough elimination of magnetic tape handling, routing paper forms for approval andshipping costs. PACS will also save the government considerable taxpayer dollars inprocessing costs associated with paper and magnetic filing and will allow for BSAinformation to be processed and made available to law enforcement investigators on anexpedited basis.”A pilot program involving 26 financial institutions, ranging from large national banks tosmall credit unions, tested the system over a two-month period this summer. FinCEN hasspent the last two months implementing enhancements suggested by the pilot participantsand allowing them time to make last minute business process changes required for fullparticipation in PACS.FinCEN is working with a competitively selected team of contractors comprised of TRWInc., Deloitte Consulting, and Deloitte & Touche to develop its e-filing system.