FinCEN Launches E-Filing System Will Allow for BSA Filing over Secure Internet

The Financial Crimes Enforcement Network (FinCEN) announced today that it has begun itspilot testing of the Patriot Act Communications System (PACS). PACS is designed to allowparticipating financial institutions to quickly and securely file Bank Secrecy Act (BSA) reportsover the Internet. Phase one of the system will allow for the filing of the bank SuspiciousActivity Report (Form TD F 90-22.47 or “SAR”) and the Currency Transaction Report (Form4789 or “CTR”).The electronic filing of BSA reports will expedite the reporting process and, thus, make theinformation available to law enforcement more rapidly. It is also designed to reduce a financialinstitution’s costs in complying with the filing of BSA reports. More than 13 million BSAreports are filed with FinCEN each year through the IRS Enterprise Computing Center-Detroit, whichprocesses the reports for FinCEN. Prior to the development of PACS, financial institutions couldfile their reports either on magnetic tape or on paper. The PACS system will provide the thirdoption of electronic filing.Approximately 30 financial institutions, ranging from large national banks to small credit unions,will pilot test the system over the next two months. All BSA information submitted to PACS isencrypted for protection.“We are optimistic that financial institutions will employ the PACS system as their filing tool ofchoice,” said James F. Sloan, Director of FinCEN. “Use of PACS will allow for BSAinformation to be processed and made available to law enforcement investigators on anexpedited basis. It will also save the government considerable taxpayer dollars in processingcosts associated with paper and magnetic filing.”Once the pilot-test phase is complete, FinCEN will evaluate the need to make adjustments to thesystem and identify opportunities for enhancement. When the system is deployed, financialinstitution personnel will be able to access PACS only after they have applied for and received adigital certificate from a Government-approved certificate authority. Financial institutions arenot mandated to use PACS.The USA Patriot Act calls for the development of a highly secure network to allow for theelectronic filing of BSA forms and to provide financial institutions with alerts comprised ofcontrol lists vetted by federal law enforcement agencies. In order to meet these requirements,FinCEN is working with a competitively selected team of contractors comprised of TRW Inc.,Deloitte Consulting, and Deloitte & Touche.