Source of the rules

The rules requiring you to report suspicious transactions come from more than one source. Each of the federal financial institution regulatory agencies has a version. These agencies and where you can find each agency’s version are:
  • The Office of the Comptroller of the Currency (OCC), regulating national banks [12 CFR 21.11];
  • The Federal Deposit Insurance Corporation (FDIC), regulating state nonmember banks [12 CFR 353.1 et seq.];
  • The Federal Reserve Board (FRB), regulating state member banks [12 CFR 208.62]; and
  • The National Credit Union Administration (NCUA), regulating credit unions

• The Office of the Comptroller of the Currency (OCC), regulating national banks [12 CFR 21.11];

[12 CFR 748.1(c)].

Furthermore, the Department of Treasury has its own version. [31 CFR 1020.320]

Fortunately, these versions are nearly identical. We will point out the differences in the appropriate places below. Citations will refer to the OCC version; finding the corresponding citation in other versions should not be difficult since the entire regulations are only a page or two. (The NCUA version appears at first glance to be different, but substantively, it is not. It incorporates by reference a large part of the Form SAR instructions, which correspond to the other agencies’ regulations.)