XMLUserGuide FinCENSAR
XMLUserGuide FinCENSAR
FinCEN SAR XML Schema User Guide (version 1.3 | January 2020) i
Financial Crimes Enforcement Network
FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) ii
Financial Crimes Enforcement Network
0. Revision History
Version Date Change Description
Number
FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) iii
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FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) iv
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FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) v
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Updated Fatal error code B9 as follows: "The element is not recorded or does
not contain a value." This is due to the fact that error code B7 is triggered if
the element is recorded but with no value (i.e. the value is null).
Modified Warning error code C25 to include the following: …and the county
code is US, CA, MX, "or a U.S. Territory."
Removed Warning error code D42 "The element is not recorded or does not
contain a value" for Item 70. Branch ID Number.
Removed Fatal error codes G17 "The element is recorded but without a value
(i.e. the value is null)" and G18 "The element contains a valid that is not a
valid code" because they are duplicates of G14 and G15, which have been
updated to be associated with both Transmitter TIN Type and Transmitter
Control Code (TCC) Type.
Removed the following Warning error codes associated with the Branch
Address sub-elements:
o D40 – The element is not recorded or does not contain a value
(RawStreetAddress1Text/69. Street)
o D43 – The element is not recorded or does not contain a value
(RawCityText/71. City)
o D48 – The element is not recorded or does not contain a value
(RawZIPCode/73. ZIP/Postal Code)
Modified Warning error code D46 as follows: “The element is not recorded or
does not contain a value when the country is US, CA, MX, or a U.S. Territory.
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FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) vii
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1.6 08/01/2021 Added ErrorCode F60 (replaces A17) – “The namespace prefix for the element is
invalid.”
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Contents
0. Revision History ............................................................................................................................................................................................... iii
Contents ...................................................................................................................................................................................................................... ix
1. Introduction .......................................................................................................................................................................................................1
2.1.5. SuspiciousActivity..........................................................................................................................................................................4
3. FinCEN SAR XML Batch Reporting Requirements ................................................................................................................................5
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5.10. Financial Institution Where Account is Held Party Record Example ...........................................................................113
6. FinCEN SAR XML Acknowledgement Format ...................................................................................................................................114
6.1.3. EFilingSubmissionXML............................................................................................................................................................115
6.1.4. EFilingActivityXML ....................................................................................................................................................................115
7.4. Financial Institution & Branch Where Activity Occurred Errors ....................................................................................128
7.5. Filing Institution Errors .................................................................................................................................................................131
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1. Introduction
The FinCEN Suspicious Activity Report (FinCEN SAR) XML Schema 2.0 User Guide outlines the business and validation
rules to support the electronic batch transmission of the FinCEN SAR. Electronic filing of this report will be through
the Bank Secrecy Act (BSA) E‐Filing System operated by the Financial Crimes Enforcement Network (FinCEN). BSA E-
Filing users who intend to file the FinCEN SAR batch XML should be familiar with FinCEN regulations, Extensible
Markup Language (XML) and the FinCEN XML schemas. For more information, please go to bsaefiling.fincen.treas.gov.
2.1.2. EFilingBatchXML
This is the root element and serves as the container for all FinCEN SAR documents recorded in the batch. It must be
the first element recorded in the file.
The EFilingBatchXML element is parent to the following complex element(s):
Activity. This element is the container for each FinCEN SAR document in the batch. All BSA data related to a
single FinCEN SAR document must be recorded within the <Activity> element. The number of <Activity>
elements will depend on the number of FinCEN SAR documents being reported in the batch.
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2.1.3. Activity
Each FinCEN SAR document in the batch must begin with the <Activity> element. It identifies all information related
to a single FinCEN SAR, including (but not limited to) the transmitter, the reporting financial institution (i.e. filing
institution), the financial institution(s) where activity occurred, the subject(s), and suspicious activity details such as the
total amount involved, type(s) of suspicious activities, etc. There is no limit to the number of <Activity> elements that
may be recorded in the batch; however, the total size of the batch file must not exceed 60MB.
The <Activity> element is parent to the following complex element(s):
ActivityAssociation. This element is the container for the type of filing (i.e. Initial report, Correct/amend
prior report, Continuing activity report, and/or Joint filing) for the FinCEN SAR.
ActivitySupportDocument. This element is the container for information about the supporting document
as an attachment to the FinCEN SAR being filed.
Party. This element is the container for any person (individual or entity) associated with the FinCEN SAR,
specifically, the transmitter [of the batch file], the transmitter contact, the filing institution and contact office,
the law enforcement contact agency and point of contact, the financial institution where activity occurred,
and the subject. NOTE: The financial institution where an account is held and the branch location where
activity occurred are not recorded at the activity level, but rather, within the corresponding party at the
activity level that the financial institution and/or branch are associated with.
SuspiciousActivity. This element is the container for information about the suspicious activity, such as the
total amount involved and the type of suspicious activity.
ActivityIPAddress. This element is the container for information about IP address involved in the suspicious
activity.
CyberEventIndicators. This element is the container for information about cyber event involved in the
suspicious activity.
Assets. This element is the container for information about asset involved in the suspicious activity,
specifically the product type, instrument type, and/or payment mechanism.
AssetsAttribute. This element is the container for information about the asset attribute involved in the
suspicious activity, whether it be a type of commodity, product/instrument, market where traded, and/or
CUSIP number.
ActivityNarrativeInformation. This element is the container for information about narrative description
associated with the FinCEN SAR.
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2.1.4. Party
Each FinCEN SAR activity in the batch must include a separate Party element identifying the following persons:
Transmitter, Transmitter Contact, Filing Institution, Designated Contact Office, Law Enforcement Agency (if any), Law
Enforcement Name (if any), Financial Institution(s) Where Activity Occurred, Branch(s) Where Activity Occurred (if any),
and Subject(s) (Note: If reporting account information related to a subject, the financial institution where the account
is held will be recorded as a separate Party element as well.). A maximum occurrence of 1203 total Party elements
may be recorded at the activity level for each FinCEN SAR activity in the batch. If one or more branches and/or
financial institutions where accounts are held are associated with a FinCEN SAR, a maximum of 99 branches and 99
financial institutions (where accounts are held) may be recorded for the FinCEN SAR in addition to the 1203 maximum
mentioned above.
Transmitter (Required)
This is the person (individual or entity) handling the data accumulation and formatting of the batch file. Each
FinCEN SAR Activity element in the batch must include a Party element that identifies the batch transmitter. The
batch transmitter should be identical for each FinCEN SAR. There must be only one occurrence of this party for
each FinCEN SAR Activity in the batch.
Transmitter Contact (Required)
This is the official contact for the transmitter. Each FinCEN SAR Activity element in the batch must include a Party
element that identifies the point of contact for the batch transmitter. The transmitter contact should be identical
for each FinCEN SAR. There must be only one occurrence of this party for each FinCEN SAR Activity in the batch.
Filing Institution (Required)
This is the entity responsible for filing the FinCEN SAR, such as a reporting financial institution or a holding or
other parent company filling for its subsidiaries. There must be only one occurrence of this party for each FinCEN
SAR Activity in the batch. This party corresponds with Part IV of the FinCEN SAR.
Designated Contact Office (Required)
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This is the administrative office that should be contacted to obtain additional information about the FinCEN SAR.
There must be only one occurrence of this party for each FinCEN SAR Activity in the batch. This party corresponds
with Part IV (Items 93-94) of the FinCEN SAR.
2.1.5. SuspiciousActivity
As the container for information about the details of the suspicious activity, this element identifies information such
as the total amount involved and the type of suspicious activity. This element must be recorded after the final Party
element is recorded for the FinCEN SAR. There must only be one occurrence of this element for each FinCEN SAR
Activity in the batch. This element corresponds with Part II (Items 29-31) of the FinCEN SAR.
Within this element is the sub-element <SuspiciousActivityClassification>, which must be recorded at least once per
FinCEN SAR (but no more than 99 total). This element is the container for information about the specific type(s) and
subtype(s) of suspicious activity, such as Structuring”Transaction(s) below CTR threshold”, Terrorist
financing”Known or suspended terrorist/terrorist group”, etc. This element corresponds with Part II (Items 32-42) of
the FinCEN SAR.
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Item Description
Element Name This is the name that must be used when recording the element.
minOccurs/maxOccurs This defines the number of times the element can occur for the parent element.
MinOccurs. The minimum number of times this element may be recorded
for the parent element (e.g. minOccurs=0 means this element is only required
under certain conditions while minOccurs=1 means at least one of the
element must be recorded for the parent element in the FinCEN SAR.)
MaxOccurs. The maximum number of times this element may be recorded
for the parent element (e.g. maxOccurs=999 means this element can occur
up to 999 times in the same FinCEN SAR.)
Description This is the summary description of the element. Also included in the description is
a list of sub-elements associated with the element (if applicable) as well as any
special requirements for when (and when not) to record the element.
Attribute(s) This specifies the attribute(s) that are required to be recorded for the element.
Note: Various elements contain the SeqNum attribute used to identify the
associated element in the batch file. The value recorded for this attribute must be
numeric and unique.
Parent Element This identifies the element’s container element. The <Parent> element contains
sub elements and is considered a complex element.
Element Restriction(s) This specifies the requirement level for the element; specifically, under what
conditions the element should be recorded:
Required. The element must be recorded for the <Parent> element.
Conditionally Required means that the element should only be recorded
when certain conditions apply.
NOTE: If neither of the above requirement levels are specified in this field,
then the element is not required. However, a field that is not required does
not mean that it is optional. All fields require an entry when the filer has the
relevant data.
Value Restriction(s) This specifies any requirements and/or restrictions in terms of the value recorded
for the element.
Required. A value must be recorded for the element.
Conditionally Required. A value may or may not be recorded for the
element depending on whether or not certain conditions apply.
Remarks This specifies any additional information about the element to assist with
reporting; including:
Reporting conditions that may result in a batch rejection.
Reporting conditions that may result in a batch accepted with warnings.
Example This provides one or more examples of how to record the element.
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IMPORTANT: FinCEN strongly encourages that filers first test their XML batch files for schema compliance using
the schemas available at www.fincen.gov/base. Your batch file should pass schema validation before you attempt
to submit to FinCEN; otherwise, it will be at risk of being rejected.
It is important to note that if the batch file does not adhere to the basic format described in this guide in accordance
with the FinCEN SAR XML batch schema, then the batch will fail validation and will not be accepted by FinCEN.
Here is a list of general schema requirements that your batch must adhere to in addition to the data requirements
described for each element throughout this guide. These schema requirements apply to all elements in the batch:
Element names must include the prefix “fc2” in both the opening tag and closing tag.
Element names must be spelled correctly and in the correct case. Do NOT included spaces at the beginning
or ending of the element names.
Elements must have a matching closing tag (which includes a self-closing tag in the event that no value is
recorded for the element).
Elements must be in the correct sequence.
Elements must be recorded when the minOccurs=1 (or greater than 1).
Elements must not be recorded more than the maxOccurs value for the associated <Parent> element.
Element values must not exceed the maximum specified character limit.
Element values must not include leading and/or trailing spaces.
Element values must not include non-printable characters, such as carriage returns, line feeds, and tabs.
Element values must not contain duplicate entries within a single activity unless expressly permitted (for
example, a Subject party type may contain one legal name and up to 99 alternate names; therefore, if more
than one legal name is recorded for the Subject, the batch file will fail validation and will not be accepted).
version The version number of the XML. The value recorded must be “1.0”
encoding The character encoding, which must be UTF-8, used for the XML. The
value recorded must be “UTF-8”
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FormTypeCode 1 1 Simple
Activity 1 unbounded Complex
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The value is null or not equal to FinCEN SARX.
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EFilingPriorDocumentNumber 0 1 Simple
FilingDateText 1 1 Simple
FilingInstitutionNotetoFinCEN 0 1 Simple
ActivityAssociation 1 1 Complex
ActivitySupportDocument 0 1 Complex
Party 6 1203 Complex
SuspiciousActivity 1 1 Complex
ActivityIPAddress 0 99 Complex
CyberEventIndicators 0 99 Complex
Assets 0 31 Complex
AssetsAttribute 0 396 Complex
ActivityNarrativeInformation 1 1 Complex
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is missing a “SeqNum” attribute.
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example: <fc2:Activity SeqNum="1">
<fc2:EFilingPriorDocumentNumber>31000000000001</fc2:EFilingPriorDocumentNumber>
<fc2:FilingDateText>20171101</fc2:FilingDateText>
<fc2:FilingInstitutionNotetoFinCEN>Filing institution note to
FinCEN</fc2:FilingInstitutionNotetoFinCEN>
<fc2:ActivityAssociation SeqNum="2">
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SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is missing a “SeqNum” attribute.
The element contains a “SeqNum” attribute with a duplicate or invalid value.
The element is recorded but none of the following sub-elements are recorded with a “Y”
value:
o <InitialReportIndicator>
o <CorrectsAmendsPriorReportIndicator>
o <ContinuingActivityReportIndicator>
The batch submission will be accepted with warning if any of the following conditions are true:
The following sub-element combinations are recorded with a “Y” value:
o <InitialReportIndicator> AND (<CorrectsAmendsPriorReportIndicator> AND/OR
<ContinuingActivityReportIndicator>)
Example: <fc2:ActivityAssociation SeqNum="2">
<fc2:ContinuingActivityReportIndicator>Y</fc2:ContinuingActivityReportIndicator>
<fc2:CorrectsAmendsPriorReportIndicator>Y</fc2:CorrectsAmendsPriorReportIndicator>
</fc2:ActivityAssociation>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityAssociation
Element Restriction(s): Conditionally Required. Record this element when the FinCEN SAR being filed corrects or amends a
previously-filed FinCEN SAR; otherwise, do not record this element.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityAssociation
Element Restriction(s): Conditionally Required. Record this element when the FinCEN SAR being filed is the first report filed on
the suspicious activity; otherwise, do not record this element.
The <InitialReportIndicator> element may be recorded on its own or in conjunction with the following
"Type of filing" element:
<JointReportIndicator>
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Initial report")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:InitialReportIndicator>Y</fc2:InitialReportIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityAssociation
Element Restriction(s): Conditionally Required. Record this element when the FinCEN SAR is being filed jointly by two or more
financial institutions; otherwise, do not record this element.
The <JointReportIndicator> element must be recorded in conjunction with at least one of the following
"Type of filing" element:
<ContinuingActivityReportIndicator>
<CorrectsAmendsPriorReportIndicator>
<InitialReportIndicator>
Furthermore, the <JointReportIndicator> element should not be recorded if one or more of the
following “subject relationship to institution” elements are indicated:
<DirectorIndicator>
<EmployeeIndicator>
<OfficerIndicator>
<OwnerShareholderIndicator>
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Joint report")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:JointReportIndicator>Y</fc2:JointReportIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) The following attributes must be recorded for this element:
Name Description
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivitySupportDocument
Element Restriction(s): Required. This element must be recorded when the associated parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: Enter the attachment file name (e.g.
FinCEN SAR_Attachment_1.csv). The attachment file must be an MS Excel-compatible comma separated
value (CSV) file with a maximum size of 1 megabyte. Include the ".csv" extension at the end of the file
name.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded with a valid value but there is no corresponding attachment.
The batch submission contains an attachment but the <OriginalAttachmentFileName>
element of the associated FinCEN SAR within the batch XML is not recorded or the value is
null.
Example: <fc2:OriginalAttachmentFileName>FinCEN SAR_Attachment.csv</fc2:OriginalAttachmentFileName>
The following tables describe all possible sub-elements for each party type at the activity level:
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3. Filing Institution (Required | FinCEN SAR Part IV, Items 75-82, 87)
5. LE Contact Agency (if available | FinCEN SAR Part IV, Item 89)
6. LE Contact Name (if available | FinCEN SAR Part IV, Items 90-92)
7. Financial Institution Where Activity Occurred (Required | FinCEN SAR Part III, Items 51-66, 69a,
68/69/70-74 if a Branch is involved)
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ActivityPartyTypeCode 1 1 Simple
AdmissionConfessionNoIndicator (Item 23b) 0 1 Simple
AdmissionConfessionYesIndicator (Item 23a) 0 1 Simple
*AllCriticalSubjectInformationUnavailableIndicator(Item 3b) 0 1 Simple
BirthDateUnknownIndicator (Item 19a) 0 1 Simple
BothPurchaserSenderPayeeReceiveIndicator (Item 28c) 0 1 Simple
FemaleGenderIndicator (Item 8b) 0 1 Simple
IndividualBirthDateText (Item 19) 0 1 Simple
MaleGenderIndicator (Item 8a) 0 1 Simple
NoKnownAccountInvolvedIndicator (Item 27a) 0 1 Simple
PartyAsEntityOrganizationIndicator (Item 3a) 0 1 Simple
PayeeReceiverIndicator (Item 28b) 0 1 Simple
PurchaserSenderIndicator (Item 28a) 0 1 Simple
UnknownGenderIndicator (Item 8c) 0 1 Simple
*PartyName (Items 4-7, 9) 1 100 Complex
*Address (Items 11-15) 1 99 Complex
PhoneNumber (Items 20, 21) 0 99 Complex
*PartyIdentification (Items 16-18) 2 100 Complex
PartyOccupationBusiness (Item 10) 0 1 Complex
ElectronicAddress (Item 22) 0 198 Complex
PartyAssociation (Items 24-26) 0 99 Complex
**PartyAccountAssociation (Items 27) 0 99 Complex
*In the event that all critical subject information is unavailable, the elements PartyName, Address, and
PartyIdentification become minOccurs “0” and should not be recorded; however, if the subject has one or
more known alternative names (which is not considered critical information), the PartyName element
would be recorded for each known subject alternative name (max 99).
**While Item 27 is associated with the subject, many of the elements associated with this item are reported
within the Financial Institution Where Account is Held (41) party type, which is nested within the Subject
(33) party type. Please refer to the Party Elements (Account Level) for more details.
Attribute(s) The following attributes must be recorded for this element:
Name Description
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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The following table describes the minimum and maximum reporting requirements per FinCEN SAR
document by party type (at the activity level):
Party type minOccurs maxOccurs
Transmitter 1 1
Transmitter Contact 1 1
Filing Institution 1 1
Filing Institution Contact Office 1 1
Law Enforcement Agency 0 1
Law Enforcement Name 0 1
Financial Institution Where Activity Occurred 1 99
Subject 1 999
35 Transmitter
37 Transmitter Contact
30 Filing Institution
8 Designated Contact Office
18 Law Enforcement Agency
19 Law Enforcement Name
34 Financial Institution Where Activity Occurred
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but with no value (i.e. the value is null).
The element contains an invalid value.
Example: <fc2:ActivityPartyTypeCode>30</fc2:ActivityPartyTypeCode>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the subject made no corroborative statement to the filer admitting to involvement in or otherwise
substantiating the suspicious activity; otherwise, do not record this element. Do not record this element
if the subject is an entity.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "No" to Corroborative
statement to filer)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AdmissionConfessionNoIndicator>Y</fc2:AdmissionConfessionNoIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the subject has made a statement to the filer admitting to involvement in or otherwise
substantiating the suspicious activity; otherwise, do not record this element. Do not record this element
if the subject is an entity.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Yes" to Corroborative
statement to filer)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AdmissionConfessionYesIndicator>Y</fc2:AdmissionConfessionYesIndicator>
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3b. Check if all critical* subject information is unavailable (does not include item *27)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and all critical* subject
information is unavailable with the exception of Item 27 “Financial Institution TIN and account
number(s) affected that are related to the subject”; otherwise, do not record this element.
*Refer to Attachment C (Item Instructions) to identify all critical items associated with the subject.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "All critical subject
information unavailable")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AllCriticalSubjectInformationUnavailableIndicator>Y</fc2:AllCriticalSubjectInformationUnavailableI
ndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the date of birth is unknown*; otherwise, do not record this element.
*If the subject is an individual and the date of birth is known, record the <IndividualBirthDateText>
element with the birth date and do not record the <BirthDateUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate date of birth unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:BirthDateUnknownIndicator>Y</fc2:BirthDateUnknownIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the LE Contact Name (19) and the most-
recent date the law enforcement agency was contacted about the suspicious activity is available;
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded for the element is not in the required format (YYYYMMDD).
Example: <fc2:ContactDateText>20171105</fc2:ContactDateText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is female; if the subject's gender is male or unknown, or the subject is an entity, do
not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate female gender)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and the date of birth is known*; otherwise, do not record this element.
*If the subject is an individual and the date of birth is unknown, record the
<BirthDateUnknownIndicator> element with a "Y" value and do not record the
<IndividualBirthDateText> element.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. If the birth day and/or month is unknown, enter “00” for the unknown day or month.
For example, a date of birth with an unknown day in February 1978 would be entered as 19780200. Do
not enter zeros for the year if the year is unknown.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The value recorded for the element is not in the required format (YYYYMMDD).
The element is not recorded for the individual Subject and both
<AllCriticalSubjectInformationUnavailableIndicator> or <BirthDateUnknownIndicator> do not
contain a “Y” value.
The date of birth recorded is less than January 1, 1900.
Example: <fc2:IndividualBirthDateText>19801025</fc2:IndividualBirthDateText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Financial institution where activity
occurred (34) and the institution has suffered a loss as a result of the suspicious activity; otherwise, do
not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 1-15 numeric characters (without
leading zeros) denominated in whole U.S. Dollars. The amount entered in this element cannot be zero
and cannot be greater than the amount recorded in the <TotalSuspiciousAmountText> element. Do not
include non-numeric characters.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is male; if the subject's gender is female or unknown, or the subject is an entity, do
not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate male gender)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
More than one gender is recorded for the Subject.
The gender is not specified for the individual Subject.
The gender “male” is specified for the entity Subject.
Example: <fc2:MaleGenderIndicator>Y</fc2:MaleGenderIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and no branch was involved in the suspicious activity (or the branch country is unknown);
otherwise, do not record this element. If this element is recorded, do not record a party type associated
with the Branch Where Activity Occurred (46) for the associated Financial Institution (34).
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "No branch activity
involved")
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and no account related to
the subject is involved in the suspicious activity; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "No known account
involved")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a “Y” value and the <PartyAccountAssociation> element is also
recorded.
The element is not recorded and the <PartyAccountAssociation element is also not recorded.
Example: <fc2:NoKnownAccountInvolvedIndicator>Y</fc2:NoKnownAccountInvolvedIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the subject is an entity;
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate that the subject is an
entity)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:PartyAsEntityOrganizationIndicator>Y</fc2:PartyAsEntityOrganizationIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the subject was the
payee or receiver of the instrument(s) or product(s) involved in the suspicious activity; otherwise, do not
record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Payee/Receiver)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
More than one role is recorded for the Subject.
Example: <fc2:PayeeReceiverIndicator>Y</fc2:PayeeReceiverIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the customer received payment from the Financial Institution (34) for the recorded
products or instruments; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Paying location")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:PayLocationIndicator>Y</fc2:PayLocationIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The element is not recorded for the approved party type (see Element Restrictions for more
information).
The element is recorded but with no value (i.e. the value is null).
The element contains an invalid value.
Example: <fc2:PrimaryRegulatorTypeCode>4</fc2:PrimaryRegulatorTypeCode>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the subject purchased
or sent the financial instrument(s) or product(s) involved in the suspicious activity; otherwise, do not
record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Purchaser/Sender)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
More than one role is recorded for the Subject.
Example: <fc2:PurchaserSenderIndicator>Y</fc2:PurchaserSenderIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the customer purchased at the financial institution (34) the recorded products or
instruments; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Selling location")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:SellingLocationIndicator>Y</fc2:SellingLocationIndicator>
56c. Financial Institution’s role in transaction: Both Selling and Paying location
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Financial Institution Where Activity
Occurred (34) and the financial institution was both the selling and paying location for the recorded
products or instruments; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate both Selling and Paying
location)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:SellingPayingLocationIndicator>Y</fc2:SellingPayingLocationIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the subject is an individual,
and subject's gender is unknown; if the subject's gender is known, or the subject is an entity, do not
record this element.
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FinCEN SAR XML Schema User Guide (version 1.6 | August 2021) 27
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b. Alternate name (if applicable | FinCEN SAR Part IV, Item 87)
4. Contact Office: Legal name (Required | FinCEN SAR Part IV, Items 93)
5. LE Contact Agency: Legal name (if applicable | FinCEN SAR Part IV, Item 89)
6. LE Contact Name: Legal name (if applicable | FinCEN SAR Part IV, Items 90)
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b. Alternate name (if applicable | FinCEN SAR Part III, Item 58)
8. Subject
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
In the event that all critical subject information is unavailable, do not record this element for
the Subject (33) unless recording the subject’s alternative name (if known).
The following table describes the minimum and maximum reporting requirements per party type (at the
activity level):
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
Subject (33), the <PartyNameTypeCode> is "L" (legal), and the legal entity/last name of the
subject is unknown.
Financial institution where activity occurred (34), the <PartyNameTypeCode> is "L" (legal),
and the institution legal name (entity or individual) is unknown.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate entity/last name
unknown)
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Conditionally Required. Record this element for the Subject (33) party type when the
<PartyNameTypeCode> is "L" (legal) and the first name of the subject is unknown; otherwise, do not
record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate first name unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:FirstNameUnknownIndicator>Y</fc2:FirstNameUnknownIndicator>
Transmitter
o Name (legal)
Transmitter Contact
o Name (legal)
Filing Institution
o 76. Filer name (legal)
o 87. Alternate name (dba/aka)
o 89. LE contact agency (legal)
o 90. LE contact name (legal)
o 93. Designated contact office (legal)
Financial Institution Where Activity Occurred
o 57. Legal name of financial institution (legal)
o 58. Alternate name (dba/aka)
Subject:
o 4. Individual’s last name or entity’s legal name (legal)
o 9. Alternate name (dba/aka)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Required. This element must be recorded.
Value Restriction(s): The value provided must adhere to the following requirements: Identify the party name type by
recording the appropriate code from the list below:
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L Legal
DBA Doing Business As*
AKA Also Known As*
*DBA and AKA name types may only be used for the following party types:
Filing Institution (30)
Financial Institution Where Activity Occurred (34)
Subject (33)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but with no value (i.e. the value is null).
The element contains an invalid value.
The element is recorded with a value that is not approved for the associated party type (see
Value Restrictions for more information).
Example: <fc2:PartyNameTypeCode>L</fc2:PartyNameTypeCode>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Conditionally Required. Record this element when the party type is associated with the Subject (33), the
<PartyNameTypeCode> is "L" (legal), and the entity/last name of the subject is known*; otherwise, do
not record this element.
*If the entity/last name of the subject is unknown, record the <EntityLastNameUnknownIndicator>
element with the value “Y” and do not record the <RawEntityIndividualLastName> element.
Value Restriction(s): The value provided must adhere to the following requirements: 150 characters or less
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value for the Subject and unknown is not
indicated.
Example: <fc2:RawEntityIndividualLastName>Mann</fc2:RawEntityIndividualLastName>
5. First name
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
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6. Middle name
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the
<PartyNameTypeCode> is "L" (legal), the subject is an individual, and the middle name is known*;
otherwise, do not record this element.
*If the subject is an individual and the middle name is unknown, this element (along with the
<PartyAsEntityOrganizationIndicator> element) should not be recorded.
Value Restriction(s): The value provided must adhere to the following requirements: 35 characters or less
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
Example: <fc2:RawIndividualMiddleName>Randy</fc2:RawIndividualMiddleName>
7. Suffix
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Record this element when the party type is associated with the Subject (33), the
<PartyNameTypeCode> is "L" (legal), the subject is an individual, and the suffix name is known*;
otherwise, do not record this element.
*If the subject is an individual and the suffix name is unknown, this element (along with the
<PartyAsEntityOrganizationIndicator> element) should not be recorded.
Value Restriction(s): The value provided must adhere to the following requirements: 35 characters or less
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Transmitter
o Name (legal)
Transmitter Contact
o Name (legal)
Filing Institution
o 76. Filer name (legal)
o 87. Alternate name (dba/aka)
o 89. LE contact agency (legal)
o 90. LE contact name (legal)
o 93. Designated contact office (legal)
Financial Institution Where Activity Occurred
o 57. Legal name of financial institution (legal)
o 58. Alternate name (dba/aka)
Subject:
o 9. Alternate name (dba/aka)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyName
Element Restriction(s): Conditionally Required. Record this element for the following party types and conditions:
The PartyNameTypeCode is “L” (legal) and the party type is associated with:
o Transmitter (35)
o Transmitter Contact (37) (NOTE: The value recorded must be the name of the
individual to be contacted on issues involving the batch file. This entry must be the
same for all FinCEN SARs in the batch file.)
o Filing Institution (30)
o Designated Contact Office (8) (NOTE: This value recorded must be the title of the
administrative office (such as Compliance Office) that should be contacted for
additional information about the FinCEN SAR.)
o LE Contact Agency (18)
o LE Contact Name (19)
o Financial Institution Where Activity Occurred (34) and the legal name is known. If
the Financial Institution (34) legal name is unknown, record the
<EntityLastNameUnknownIndicator> element with the value “Y” and do not record
the <RawPartyFullName> element.
The PartyNameTypeCode is “DBA” or "AKA" and the party type is associated with:
o Filing institution* (30)
o Financial Institution Where Activity Occurred* (34)
o Subject* (33)
*If there is no DBA or AKA name for the above party types, only record the <PartyName> element
associated with the legal name.
Value Restriction(s): The value provided must adhere to the following requirements: 150 characters or less
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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RawCityText 1 1 Simple
RawCountryCodeText 1 1 Simple
RawStateCodeText 1 1 Simple
RawStreetAddress1Text 1 1 Simple
RawZIPCode 1 1 Simple
2. Filing Institution Information: Address (Required | FinCEN SAR Part IV, Items 82-86)
3. Financial Institution Where Activity Occurred: Address/Unknown (Required | FinCEN SAR Part
III, Items 61-65)
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SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Transmitter 1-1
Filing Institution 1-1
Financial Institution Where Activity Occurred 1-1
Subject* 0-99
*In the event that all critical subject information is unavailable, do not record the <Address> element for
the Subject (33).
Value Restriction(s): n/a
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The element is missing a “SeqNum” attribute.
The element contains a “SeqNum” attribute with a duplicate or invalid value.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element when the city is unknown* for the following party types:
Financial institution where activity occurred (34)
Subject (33)
*If the city is known, record the <RawCityText> element with city name and do not record the
<CityUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate city unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:CityUnknownIndicator>Y</fc2:CityUnknownIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element when the country is unknown* for the following party
types:
Financial institution where activity occurred (34)
Subject (33)
*If the country is known, record the <RawCountryCodeText> element with the ISO 3166-2 country code
and do not record the <CountryCodeUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate country unknown)
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Transmitter: City
Subject: 12. City
Financial Institution Where Activity Occurred: 62. City
Filing Institution: 83. City
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Required. This element must be recorded for the following party types:
Transmitter (35)
Filing institution (30)
Conditionally Required. Record this element when the city is known* for the following party types:
Subject (33)
Financial institution where activity occurred (34)
*If the city is unknown, record the <CityUnknownIndicator> element with the value “Y” and do not
record the <RawCityText> element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
The element is not recorded or does not contain a value for the transmitter or filing
institution.
Example: <fc2:RawCityText>Tysons Corner</fc2:RawCityText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Required. This element must be recorded for the following party types:
Transmitter (35)
Filing institution (30)
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Transmitter: State
Subject: 13. State
Financial Institution Where Activity Occurred: 63. State
Filing Institution: 84. State
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element for the following party types when the corresponding
country is US (United States), CA (Canada), MX (Mexico), or a U.S. Territory*; otherwise, do not record
this element:
Transmitter (35)
Filing institution (30)
Subject (33) and the state is known**
Financial institution where activity occurred (34)
*If the country is a U.S. Territory, record the same U.S. Territory code for the state.
**If the subject's state is unknown, record the <StateCodeUnknownIndicator> element with the value
“Y” and do not record the <RawStateCodeText> element.
Value Restriction(s): The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not a valid state code.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value for the transmitter or filing
institution when the country is US, CA, MX, or a U.S. Territory.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Required. This element must be recorded for the following party types:
Transmitter (35)
Filing institution (30)
Conditionally Required. Record this element when the street address is known* for the following party
types:
Subject (33)
Financial institution where activity occurred (34)
*If the street address is unknown, record the <StreetAddressUnknownIndicator> element with the value
“Y” and do not record the <RawStreetAddress1Text> element.
Value Restriction(s): The value provided must adhere to the following requirements: 100 characters or less
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value for the subject or the financial
institution where activity occurred and unknown is not indicated.
The element is not recorded or does not contain a value for the transmitter or filing
institution.
Example: <fc2:RawStreetAddress1Text>987 Rocky Road</fc2:RawStreetAddress1Text>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Required. This element must be recorded for the following party types:
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element for the Subject (33) party type when the state is unknown*
and the corresponding country is US (United States), CA (Canada), or MX (Mexico); otherwise, do not
record this element.
*If the subject's state is known, record the <RawStateCodeText> element with ISO 3166-2 state code
and do not record the <StateCodeUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate state unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:StateCodeUnknownIndicator>Y</fc2:StateCodeUnknownIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element when the street address is unknown* for the following
party types:
Subject (33)
Financial institution where activity occurred (34)
*If the street address is known, record the <RawStreetAddress1Text> element with street address and
do not record the <StreetAddressUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate street address unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:StreetAddressUnknownIndicator>Y</fc2:StreetAddressUnknownIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Conditionally Required. Record this element when the ZIP/Postal Code is unknown* for the following
party types:
Subject (33)
Financial institution where activity occurred (34)
*If the ZIP/Postal Code is known, record the <RawZIPCode> element with the code and do not record
the <ZIPCodeUnknownIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate ZIP/Postal code
unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:ZIPCodeUnknownIndicator>Y</fc2:ZIPCodeUnknownIndicator>
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PhoneNumberText 1 1 Simple
2. Contact Office: Telephone (Required | FinCEN SAR Part IV, Item 94)
3. LE Contact Name: Telephone (If applicable | FinCEN SAR Part IV, Item 91)
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Transmitter 1-1
Contact Office 1-1
LE Contact Name 0-1
Subject 0-99
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PhoneNumber
Element Restriction(s): Record this element when the telephone number extension is known for the following party types;
otherwise, do not record this element:
Subject (33)
LE Contact Name (19)
Contact Office (8)
Value Restriction(s): The value provided must adhere to the following requirements: 6 numeric characters or less
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
Example: <fc2:PhoneNumberExtensionText>5584</fc2:PhoneNumberExtensionText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PhoneNumber
Element Restriction(s): Record this element for the following party types and circumstances; otherwise, do not record this
element:
Transmitter (35)Contact Office (8)
Subject (33) and the telephone number is known
LE Contact Name (19) and the telephone number is known
Value Restriction(s): The value provided must adhere to the following requirements by party type:
Transmitter (35)
o 10 numeric characters; not all same digit (such as all 0’s or all 9’s). NOTE: This
number must be the same for all FinCEN SARs in the batch file.
Contact Office (8) / Subject (3) / LE Contact Name (19)
o 16 numeric characters or less; not all same digit (such as all 0’s or all 9’s)
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PhoneNumber
Element Restriction(s): Record this element for the Subject (33) party type when a phone number is recorded with the
<PhoneNumberText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: Identify the phone number type by
recording the appropriate code from the list below:
Code Description
R Residence (Home)
W Work
M Mobile
F Fax
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is an invalid code.
Example: <fc2:PhoneNumberTypeCode>R</fc2:PhoneNumberTypeCode>
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1. Transmitter Information
PartyIdentificationNumberText 1 1 Simple
PartyIdentificationTypeCode (Code 28) 1 1 Simple
PartyIdentificationNumberText 1 1 Simple
PartyIdentificationTypeCode (Code 4) 1 1 Simple
2. Filing Institution
a. TIN (EIN, SSN/ITIN, Foreign) (Required | FinCEN SAR Part IV, Item 77-78)
b. Filing institution identification (CRD, IARD, etc.) (if applicable | FinCEN SAR Part IV,
Item 81)
c. Internal control/file number (if available | FinCEN SAR Part IV, Item 88)
a. TIN (EIN, SSN/ITIN, Foreign) (Required | FinCEN SAR Part III, Item 59-60)
b. Financial institution identification (CRD, IARD, etc.) (if applicable | FinCEN SAR Part
III, Item 55)
c. Internal control/file number (if available | FinCEN SAR Part III, Item 66)
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4. Subject
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Record this element when all information related to the Subject (33) form of identification is unknown;
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Identification unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:IdentificationPresentUnknownIndicator>Y</fc2:IdentificationPresentUnknownIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Record this element for the Subject (33) party type when the following conditions are true; otherwise,
do not record this element:
The identification type is Passport or Alien registration
The identification type is Driver’s license/state ID or Other, and the country the identification
was issued in is known
Value Restriction(s): The value provided must adhere to the following requirements: Country codes (including U.S. Territory
codes) must adhere to the two-letter country codes found in ISO 3166-2.
Remarks: The batch submission will be rejected if any of the following conditions are true:
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Record this element for the Subject (33) party type when the following conditions are true; otherwise,
do not record this element:
The identification type is Driver's license/state ID and the corresponding country is US, CA,
MX, or a U.S. Territory
The identification type is Other and the identification was issued by or in a known
state/province/territory of the U.S., a U.S. Territory, Canada, or Mexico.
The identification type is Other and the identification was not issues by a national
government.
Value Restriction(s): The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value for the Subject when the form of
identification is Driver’s license/State ID.
The element contains a value and identification unknown is indicated.
The element contains a value that is not a valid state code.
State code and country code mismatch when U.S. Territory is recorded.
Example: <fc2:OtherIssuerStateText>CA</fc2:OtherIssuerStateText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
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Transmitter
o Transmitter Control Code (TCC) number
o Taxpayer Identification Number (TIN) number
Filing Institution
o 77. TIN (EIN, SSN/ITIN, Foreign) number
o 81. Filing institution identification (CRD, IARD, etc.) number (if known)
o 88. Internal control/file number (if known)
Subject
o 16. TIN (EIN, SSN/ITIN, Foreign) number (if known)
o 18. Form of identification (Driver’s license/State ID, Passport, etc.) number (if
known)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Conditionally Required. Record this element for the above party types and conditions, otherwise, do not
record this element. If unknown is indicated for the Financial Institution TIN or the Subject TIN, record
the corresponding unknown element with a “Y” value and do not record this element. For Form of
Identification do not record this element when unknown is indicated but only record the corresponding
unknown element with a "Y" when all Form of Identification data are unknown.
Value Restriction(s): The value provided must adhere to the following requirements by party type:
Transmitter (35)
o TCC = 8 characters equal to “TBSATEST” (when submitting in the BSA E-Filing User
Test System) or “PBSA8180” (when submitting in the BSA E-Filing Production
System)
o TIN = 25 characters or less
Filing institution (30) and Financial institution where activity occurred (34)
o EIN/SSN/ITIN = 9 numeric characters
o Foreign TIN = 25 characters or less
o Identification number (CRD, IARD, etc.) = 10 characters or less
o Internal Control Number = 20 characters or less
Subject (33)
o EIN/SSN/ITIN = 9 numeric characters
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Transmitter
o Transmitter Control Code (TCC) type
o Taxpayer Identification Number (TIN) type
Filing Institution
o 78. TIN (EIN, SSN/ITIN, Foreign) type
o 81. Filing institution identification (CRD, IARD, etc.) type
o 88. Internal control/file number type
Subject
o 17. TIN (EIN, SSN/ITIN, Foreign) type
o 18. Form of identification (Driver’s license/State ID, Passport, etc.) type
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Required. This element must be recorded for the above party types/conditions; otherwise, do not record
this element.
Value Restriction(s): The value provided must adhere to the following requirements: Identify the identification type by
recording the appropriate code from the list below (by party type at the activity level):
Code Description Party Type (Code)
35 30 34 33
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded and the <PartyIdentificationNumberText> contains a value.
The element contains a value not equal to one of the approved codes listed above.
The element is recorded but without a value (i.e. the value is null).
The element contains a value that is not valid for the associated party type.
Example: <fc2:PartyIdentificationTypeCode>999</fc2:PartyIdentificationTypeCode>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Conditionally Required. Record this element for the Financial institution where activity occurred (34) and
Subject (33) part types when the TIN is unknown; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate TIN unknown)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:PartyIdentification SeqNum="69">
<fc2:TINUnknownIndicator>Y</fc2:TINUnknownIndicator>
</fc2:PartyIdentification>
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1. Filing Institution Information: Type of financial institution (Required | FinCEN SAR Part IV,
Items 79-80)
2. Financial Institution Where Activity Occurred: Type of financial institution (Required | FinCEN
SAR Part III, Items 51, 53-54)
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Filing institution
o 80a-n, z. Type of Securities and Futures institution or individual
Financial institution where activity occurred
o 53a-c, z. Type of Gaming institution
o 54a-k, z. Type of Securities and Futures institution or individual
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: OrganizationClassificationTypeSubtype
Element Restriction(s): Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
Filing institution (30) and the type of institution is Securities/Futures (5)
Financial institution where activity occurred (34) and the type of institution is either
Casino/Card club (1) or Securities/Futures (5)
Value Restriction(s): The value provided must adhere to the following requirements:
If the party type is associated with the Filing institution (30) or Filing institution where activity
occurred (34) and the type of institution is Securities/Futures (5), then select from the list of
codes to describe the institution subtype:
Code Description Party Type (Code)
30 34
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
The element contains a value but the institution type is not equal to Casino/Card club or
Securities and Futures.
The value recorded conflicts with the institution type recorded (e.g. State Casino recorded for
Securities and Futures institution)
The element is not recorded for the filing institution and the institution type is equal to
Securities and Futures.
The element is not recorded for the financial institution where activity occurred and the
institution type is equal to Casino/Card club or Securities and Futures.
The element contains a value that has already been recorded for the Activity.
Example: <fc2:OrganizationSubtypeID>103</fc2:OrganizationSubtypeID>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: OrganizationClassificationTypeSubtype
Element Restriction(s): Required. This element must be recorded when the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Identify the institution type by recording the appropriate code from the list below:
Code Description
1 Casino/Card club
2 Depository institution
3 Insurance company
4 MSB (Money Service Business)
5 Securities/Futures
11 Loan or Finance Company
12 Housing GSE (Government Sponsored Enterprise)
999 Other
Remarks: The batch submission will be rejected if any of the following conditions are true:
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Filing institution
o 80z. Type of Securities and Futures institution or individual (other description)
Financial institution where activity occurred
o 53z. Type of Gaming institution (other description)
o 54z. Type of Securities and Futures institution or individual (other description)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: OrganizationClassificationTypeSubtype
Element Restriction(s): Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
Filing institution (30), the type of institution is Securities/Futures (5), and the
<OrganizationSubtypeID> element contains the value "5999" (Other)
Financial institution where activity occurred (34) and:
o The type of institution is Casino/Card club (1) and the <OrganizationSubtypeID>
element contains the value "1999" (Other)
o The type of institution is Securities/Futures (5) and the <OrganizationSubtypeID>
element contains the value "5999" (Other)
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value and the institution subtype is equal
to Other.
The element is recorded with a value but the institution subtype is not equal to Other.
Example: <fc2:OtherOrganizationSubTypeText>other description</fc2:OtherOrganizationSubTypeText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: OrganizationClassificationTypeSubtype
Element Restriction(s): Conditionally Required. Record this element for the following party types and conditions; otherwise, do
not record this element:
Filing institution (30) and the <OrganizationTypeID> element contains the value "999" (Other)
Financial institution where activity occurred (34) and the <OrganizationTypeID> element
contains the value "999" (Other)
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
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1. Subject: Occupation or type of business (if available | FinCEN SAR Part I, Item 10/10a)
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Please refer to Attachment C for additional information regarding the above item(s).
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyOccupationBusiness
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the subject's
occupation, profession, or type of business is known; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less
Remarks: n/a
Example: <fc2:OccupationBusinessText>Mechanic</fc2:OccupationBusinessText>
1. Subject:
b. Website (URL) address (if available | FinCEN SAR Part I, Item 22a)
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SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
The following table describes the minimum and maximum reporting requirements for this element:
Subject
o 22. E-mail address (if available)
o 22a. Website (URL) address (if available)
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ElectronicAddress
Element Restriction(s): Record this element when the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
E-mail address: 50 characters or less; the value must contain the "@" sign followed by at least
one period (e.g. [email protected])
Website (URL) address: 517 characters or less; the values should contain at least one period.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The value recorded for the element is not a valid email address or URL format.
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Subject
o 22. E-mail address type
o 22a. Website (URL) type
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ElectronicAddress
Element Restriction(s): Record this element when the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Identify the electronic address type by recording the appropriate code from the list below:
Code Description
E E-mail address
U Website (URL) address
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded or does not contain a value (i.e. the value is null).
The value recorded is an invalid code.
Example: <fc2:ElectronicAddress SeqNum="74">
<fc2:ElectronicAddressText>[email protected]</fc2:ElectronicAddressText>
<fc2:ElectronicAddressTypeCode>E</fc2:ElectronicAddressTypeCode>
</fc2:ElectronicAddress>
<fc2:ElectronicAddress SeqNum="75">
<fc2:ElectronicAddressText>https://www.will_mann.org/</fc2:ElectronicAddressText>
<fc2:ElectronicAddressTypeCode>U</fc2:ElectronicAddressTypeCode>
</fc2:ElectronicAddress>
The following tables describe all possible sub-elements for each activity level party type:
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1. Subject: Relationship of subject to an institution recorded in Part III or IV (FinCEN SAR Part I,
Items 24-26)
2. Financial institution where activity occurred: Branch location (FinCEN SAR Part III, Items 68, 69,
70-74)
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
The party recorded is associated with the Subject (33) and the relationship of the subject to
the filing institution and/or the financial institution(s) where activity occurred is being
recorded..
NOTE: If the subject does not have a relationship with any of the recorded institutions in Part
III or IV, record a single <PartyAssociation> element for the subject where the element
<NoRelationshipToInstitutionIndicator> is recorded with a "Y" value and the TIN of the filing
institution is recorded for the <SubjectRelationshipFinancialInstitutionTINText> element. The
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The party recorded is associated with the financial institution where activity occurred (34) and
activity occurred at a branch location.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the status of the subject
relationship to the institution TIN recorded for the <SubjectRelationshipFinancialInstitutionTINText>
element has be identified as Terminated, Suspended/barred, or Resigned; otherwise, do not record this
element.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value and the status of the relationship is
Terminated, Suspended/barred, or Resigned.
The element is recorded with a valid value but the status of the relationship is not equal to
Terminated, Suspended/barred, or Resigned.
The value recorded for the element is not in the required format (YYYYMMDD).
Example: <fc2:ActionTakenDateText>20170905</fc2:ActionTakenDateText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Agent)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Appraiser)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AppraiserIndicator>Y</fc2:AppraiserIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Attorney)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AttorneyIndicator>Y</fc2:AttorneyIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Customer)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:CustomerIndicator>Y</fc2:CustomerIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Director)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a “Y” value for the subject and <JointReportIndicator> contains
a “Y” value.
Example: <fc2:DirectorIndicator>Y</fc2:DirectorIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Employee)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a “Y” value for the subject and <JointReportIndicator> contains
a “Y” value.
Example: <fc2:EmployeeIndicator>Y</fc2:EmployeeIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the subject does not
have a relationship with filing institution or financial institution(s) where activity occurred*; otherwise, do
not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "No relationship to an
institution")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:NoRelationshipToInstitutionIndicator>Y</fc2:NoRelationshipToInstitutionIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Officer)
Remarks: The batch submission will be rejected if any of the following conditions are true:
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when the party type is associated with the Subject (33) and the
<OtherRelationshipIndicator> element contains a "Y" value; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value and Other is indicated.
The element is recorded with a value and Other is not indicated.
Example: <fc2:OtherPartyAssociationTypeText>Other description</fc2:OtherPartyAssociationTypeText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element cannot be categorized by one of the
pre-defined indicator elements; otherwise, do not record this element. If this element is recorded with a
"Y" value, please ensure a brief description of the relationship type is recorded in the
<OtherPartyAssociationTypeText> element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Other relationship")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:OtherRelationshipIndicator>Y</fc2:OtherRelationshipIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element when it describes the relationship of the subject (33) to the institution TIN recorded
in the <SubjectRelationshipFinancialInstitutionTINText> element; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Owner or controlling
shareholder")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a “Y” value for the subject and <JointReportIndicator> contains
a “Y” value.
Example: <fc2:OwnerShareholderIndicator>Y</fc2:OwnerShareholderIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
<SubjectRelationshipFinancialInstitutionTINText> element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Relationship
continues")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Example: <fc2:RelationshipContinuesIndicator>Y</fc2:RelationshipContinuesIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
<SubjectRelationshipFinancialInstitutionTINText> element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Resigned)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Example: <fc2:ResignedIndicator>Y</fc2:ResignedIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element for the Subject (33) party type in order to identify the TIN (if known) associated
with the filing institution or financial institution where activity occurred in which the subject has a
relationship with; otherwise, do not record this element. If the subject has no relationship with any of
these institutions, record the TIN of the filing institution for this element and record a "Y" value for the
<NoRelationshipToInstitutionIndicator> element.
Value Restriction(s): The value provided must adhere to the following requirements: 25 characters or less. The number
recorded must match the TIN recorded for the filing institution or the financial institution where activity
occurred.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded does not match the TIN for the Filing institution or the Financial
institution where the activity occurred.
Example: <fc2:SubjectRelationshipFinancialInstitutionTINText>458789856</fc2:SubjectRelationshipFinancialInstit
utionTINText>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAssociation
Element Restriction(s): Record this element for the Subject (33) party type when it best describes the status of the relationship
when the subject’s relationship to the institution TIN recorded for the
<SubjectRelationshipFinancialInstitutionTINText> element has been identified as Director, Employee,
Officer, or Owner/Controlling Shareholder; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate Terminated)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is recorded with a valid value but the type of relationship is not equal to
Director, Employee, Officer, or Owner/Controlling Shareholder.
The element is not recorded or does not contain a value and the type of relationship is equal
to Director, Employee, Officer, and/or Owner/Controlling Shareholder.
Example: <fc2:TerminatedIndicator>Y</fc2:TerminatedIndicator>
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The following tables describe all possible sub-elements for the Branch (46) party type:
1. Financial institution where activity occurred: Branch location (FinCEN SAR Part III, Items 68, 69,
70-74)
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Branch Where Activity Occurred (46) and
the customer received payment from the branch (46) for the recorded products or instruments;
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Paying location")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
More than one role is recorded for the branch’s role in the transaction.
Example: <fc2:PayLocationIndicator>Y</fc2:PayLocationIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Branch Where Activity Occurred (46)
and the branch sold the recorded products or instruments; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Selling location")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
More than one role is recorded for the branch’s role in the transaction.
Example: <fc2:SellingLocationIndicator>Y</fc2:SellingLocationIndicator>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the party type is associated with the Branch Where Activity Occurred (46) and
the branch was both the selling and paying location for the recorded products or instruments;
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate both Selling and Paying
location)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is recorded for a party type that is not applicable to this data (see Element
Restrictions for more information).
The value recorded is not equal to “Y” or not equal to null.
The batch submission will be accepted with warnings if any of the following conditions are true:
More than one role is recorded for the branch’s role in the transaction.
Example: <fc2:SellingPayingLocationIndicator>Y</fc2:SellingPayingLocationIndicator>
RawCityText 0 1 Simple
RawCountryCodeText 1 1 Simple
RawStateCodeText 0 1 Simple
RawStreetAddress1Text 0 1 Simple
RawZIPCode 0 1 Simple
*If the <Address> element is recorded for the Branch (46) party type, then the <RawCountryCodeText>
must contain a value in addition to any other known address elements.
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Record this element for the Branch (46) where activity occurred party type when the city associated
with the branch address is known; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less
Remarks: None
Example: <fc2:RawCityText>Rockville</fc2:RawCityText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: Country codes (including U.S. Territory
codes) must adhere to the two-letter country codes found in ISO 3166-2.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not a valid country code.
The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value.
State code and country code mismatch when U.S. Territory is recorded.
Example: <fc2:RawCountryCodeText>US</fc2:RawCountryCodeText>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Record this element for the Branch (46) where activity occurred party type and the corresponding
country is US (United States), CA (Canada), MX (Mexico), or a U.S. Territory*; otherwise, do not record
this element.
*If the country is a U.S. Territory, record the same U.S. Territory code for the state.
Value Restriction(s): The value provided must adhere to the following requirements: United States state/territory codes must
adhere to the two-letter codes used by the United States Postal Service when the country is equal to US
or a U.S. Territory. If a U.S. Territory is recorded for the country, it must also be recorded for the state.
Canadian province/territory codes must adhere to the two-letter codes used by the Canadian Post
Corporation when the country is equal to CA. Mexican state/federal district codes must adhere to the
standards of ISO 3166-2:MX when the country is equal to MX.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not a valid country code.
The batch submission will be accepted with warning if any of the following conditions are true:
The element contains a value and the country is not US, CA, MX, or a U.S. Territory.
The element is not recorded or does not contain a value when the country is US, CA, MX, or a
U.S. Territory.
State code and country code mismatch when U.S. Territory is recorded.
Example: <fc2:RawStateCodeText>VA</fc2:RawStateCodeText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
Element Restriction(s): Record this element for the Branch (46) where activity occurred party type when the street address
associated with the branch address is known; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 100 characters or less
Remarks: None
Example: <fc2:RawStreetAddress1Text>123 Address Way</fc2:RawStreetAddress1Text>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Address
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The following tables describe all possible sub-elements for the Branch (46) party type:
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: “14” (to identify the number recorded
as the RSSD number)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded or does not contain a value
The value recorded is not equal to “14”.
Example: <fc2:PartyIdentificationTypeCode>14</fc2:PartyIdentificationTypeCode>
ALERT: This is the end of the elements associated with the Part III Branch location where activity occurred.
The following PartyAccountAssociation element corresponds with the Subject party type only.
1. Subject: Financial institution TIN and account number(s) affected that are related to the
subject (if any) (FinCEN SAR Part I, Item 27b-e)
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SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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account(s) are held may be reported for each subject. Please refer to the Item 27 Item Instructions (Attachment C) for
additional information.
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but with no value (i.e. the value is null).
The element contains a value not equal to “41”.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Party
Element Restriction(s): Record this element when the Financial institution where the account is held (41) party type and the
location of the institution is not within the U.S. or a U.S. Territory; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Non U.S. financial
institution)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:NonUSFinancialInstitutionIndicator>Y</fc2:NonUSFinancialInstitutionIndicator>
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is missing a “SeqNum” attribute.
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example: <fc2:PartyIdentification SeqNum="81">
<fc2:PartyIdentificationNumberText>458789856</fc2:PartyIdentificationNumberText>
<fc2:PartyIdentificationTypeCode>4</fc2:PartyIdentificationTypeCode>
</fc2:PartyIdentification>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Required. Record this element if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: 25 characters or less. Identification
numbers must be entered as a single alpha/numeric text string without formatting or special characters
such as, for example, spaces, hyphens, or periods. Cannot be consecutive string of the same number or
an incremental string such as 123456789.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value.
Example: <fc2:PartyIdentificationNumberText>458789856</fc2:PartyIdentificationNumberText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyIdentification
Element Restriction(s): Required. Record this element if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: “4” (to indicate TIN)
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded or does not contain a value.
The value recorded does not equal “4”.
Example: <fc2:PartyIdentificationTypeCode>4</fc2:PartyIdentificationTypeCode>
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SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
*An account is related to a subject if the subject owns the account, has control over the account, or
conducted activity in or through an account the subject does not own or control.
**If the filer is aware that the subject has an account involved in the suspicious activity with the
recorded financial institution but the account number is unknown, record the
<PartyIdentificationNumberText> element with the TIN of the financial institution (41) party type and
do not record the <Account> element. Provide an explanation for the missing account number in the
narrative.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Account
Element Restriction(s): Required. This element must be recorded when the <Account> parent element is recorded.
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1. Subject: Financial institution TIN and account number(s) affected that are related to the
subject (if any) (FinCEN SAR Part I, Item 27e)
AccountClosedIndicator 0 1 Simple
PartyAccountAssociationTypeCode (Code 5) 1 1 Simple
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is missing a “SeqNum” attribute.
The element contains a “SeqNum” attribute with a duplicate or invalid value.
Example: <fc2:PartyAccountAssociation SeqNum="83">
<fc2:AccountClosedIndicator>Y</fc2:AccountClosedIndicator>
<fc2:PartyAccountAssociationTypeCode>5</fc2:PartyAccountAssociationTypeCode>
</fc2:PartyAccountAssociation>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: PartyAccountAssociation
Element Restriction(s): Record this element for the Financial institution where the account is held (41) party type when the
associated account is closed; otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Account closed")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element contains a value not equal to “Y” or null.
Example: <fc2:AccountClosedIndicator>Y</fc2:AccountClosedIndicator>
ALERT: This is the end of the elements associated with the Part I Item 27 Financial institution TIN and account
number(s) affected that are related to the subject. The following SuspiciousActivity element corresponds with the
FinCEN SAR activity.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivity
Element Restriction(s): Record this element when the dollar amount involved in the FinCEN SAR being filed is unknown;
otherwise, do not record this element. If unknown, provide an explanation as to why the dollar amount
is unknown in narrative. If some dollar amounts are known while others are unknown, do not record the
AmountUnknownIndicator element; instead, record the total of all known amounts in the
TotalSuspiciousAmountText element and provide an explanation for the unknown amounts in the
narrative.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "Amount unknown")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:AmountUnknownIndicator>Y</fc2:AmountUnknownIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivity
Element Restriction(s): Record this element when there is no amount involved in the suspicious activity; otherwise, do not
record this element.
Value Restriction(s): The value provided must adhere to the following requirements: "Y" (to indicate "No amount involved")
Remarks: The batch submission will be rejected if any of the following conditions are true:
The value recorded is not equal to “Y” or not equal to null.
Example: <fc2:NoAmountInvolvedIndicator>Y</fc2:NoAmountInvolvedIndicator>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivity
Element Restriction(s): Required. This element must be recorded.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. If the exact date(s) of the suspicious activity is (are) unknown, enter a date range
that the filer believes will encompass the date(s) of the suspicious activity. Explain the nature of this date
range in the narrative. If the FinCEN SAR involves continuing activity, enter only the date range covered
by this FinCEN SAR. Record in the narrative the aggregated date range of all FinCEN SARs filed on the
continuing suspicious activity.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivity
Element Restriction(s): Record this element when the suspicious activity occurred on multiple days (in which case this element
will record the most-recent date of suspicious activity); otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero. If the exact date(s) of the suspicious activity is (are) unknown, enter a date range
that the filer believes will encompass the date(s) of the suspicious activity. Explain the nature of this date
range in the narrative. If the FinCEN SAR involves continuing activity, enter only the date range covered
by this FinCEN SAR. Record in the narrative the aggregated date range of all FinCEN SARs filed on the
continuing suspicious activity.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The value recorded for the element is not in the required format (YYYYMMDD).
Example: <fc2:SuspiciousActivityToDateText>20171030</fc2:SuspiciousActivityToDateText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivity
Element Restriction(s): Record this element when there is an amount involved in the FinCEN SAR and some or all of the dollar
amounts are known. Otherwise, do not record this element and instead, record either the
AmountUnknownIndicator element with a "Y" value if the entire amount is unknown, or the
NoAmountInvolvedIndicator element with a "Y" value if there is no amount involved in the FinCEN SAR.
If some dollar amounts are known while others are unknown, do not record the
AmountUnknownIndicator element; instead, record the total of all known amounts in the
TotalSuspiciousAmountText element and provide an explanation for the unknown amounts in the
narrative.
Value Restriction(s): The value provided must adhere to the following requirements: 1-15 numeric characters (without
leading zeros) denominated in whole U.S. Dollars.
Remarks: The batch submission will be accepted with warnings if any of the following conditions are true:
The value recorded contains one or more non-numeric characters.
The element is not recorded or does not contain a value and unknown or no amount involved
in not indicated.
The element is recorded with a value and unknown or no amount involved is indicated.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) The following attributes must be recorded for this element:
Name Description
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivityClassification
Element Restriction(s): Conditionally Required. Record this element when the type of suspicious activity is recorded as "Other"
(i.e. <SuspiciousActivitySubtypeID> contains any of the following codes:
1999,3999,4999,5999,6999,7999,8999,9999,10999,11999,12999); otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The element is not recorded or does not contain a value and the subtype of suspicious
activity is equal to Other.
The element is recorded with a value but the subtype of suspicious activity is not equal to
Other.
Example: <fc2:OtherSuspiciousActivityTypeText>other type of suspicious activity
description</fc2:OtherSuspiciousActivityTypeText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivityClassification
Element Restriction(s): Required. This element must be recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Record the subtype code from the lists below to identify the specific suspicious activity
subtype for the following:
o Structuring (1)
Code Description
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Code Description
o Fraud (3)
Code Description
320 ACH
322 Advance fee
321 Business loan
301 Check
304 Consumer Loan
305 Credit/Debit Card
323 Healthcare/Public or private health insurance
308 Mail
309 Mass-marketing
324 Ponzi scheme
310 Pyramid scheme
325 Securities fraud
312 Wire transfer
3999 Other
Code Description
Code Description
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Code Description
Code Description
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o Insurance (5)
Code Description
o Securities/Futures/Options (6)
Code Description
Code Description
Code Description
Remarks: The batch submission will be rejected if any of the following conditions are true:
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32. Structuring
33. Terrorist financing
34. Fraud
35. Gaming activities
36. Money Laundering
37. Identification/Documentation
38. Other suspicious activities
39. Insurance
40. Securities/Futures/Options
41. Mortgage fraud
42. Cyber event
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: SuspiciousActivityClassification
Element Restriction(s): Required. This element must be recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Record the type code from the list below to identify the specific suspicious activity type:
Code Description
1 Structuring
7 Terrorist financing
3 Fraud
12 Gaming activities
8 Money Laundering
4 Identification / Documentation
9 Other suspicious activities
5 Insurance
6 Securities/Futures/Options
10 Mortgage fraud
11 Cyber event
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
Example: <fc2:SuspiciousActivityTypeID>6</fc2:SuspiciousActivityTypeID>
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) The following attributes must be recorded for this element:
Name Description
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityIPAddress
Element Restriction(s): Record this element to identify the date of the first instance of the reported IP Address (if known);
otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityIPAddress
Element Restriction(s): Record this element to identify the Coordinated Universal Time (UCT) associated with the first instance
of the reported IP Address (if known); otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: UCT time must be in the format
"HH:MM:SS" where HH = hour (00-23), MM = minutes (00-59), and SS = second (00-59). Single digit
times must be prefaced by a zero.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The value recorded for the element is not in the required format (HH:MM:SS).
Example: <fc2:ActivityIPAddressTimeStampText>05:13:55</fc2:ActivityIPAddressTimeStampText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: ActivityIPAddress
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: If the IP address is IPv4, use a variation
of the format nnn.nnn.nnn.nnn (n = number) with periods between the segments. First set of numbers
must be values between 1-255 (inclusive); second, third and fourth set of numbers must be values
between 0-255 (inclusive).
If the IP address is IPv6, use a variation of the format cccc:cccc:cccc:cccc:cccc:cccc:cccc:cccc (c =
character, IPv6 is alphanumeric in some segments) with colons between the segments.
Remarks: The batch submission will be accepted with warning if any of the following conditions are true:
The value recorded for the element is not in the required format (see Value Restrictions for
format requirements).
Example: <fc2:IPAddressText>166.123.216.61</fc2:IPAddressText>
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Please refer to Attachment C for additional information regarding the above item(s).
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: CyberEventIndicators
Element Restriction(s): Record this element to identify the date associated with the following cyber events (if known);
otherwise, do not record this element:
Command and Control IP Address
Suspicious IP Address
Value Restriction(s): The value provided must adhere to the following requirements: 8 numeric characters in the format
YYYYMMDD where YYYY = year, MM = month, and DD = day. Single digit days or months must be
prefaced by a zero.
Remarks: The batch submission will be rejected if any of the following conditions are true:
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: CyberEventIndicators
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Record the type of cyber event indicator from the list below:
Code Description
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded or does not contain a value.
The value recorded is invalid.
Example: <fc2:CyberEventIndicatorsTypeCode>1</fc2:CyberEventIndicatorsTypeCode>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: CyberEventIndicators
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: CyberEventIndicators
Element Restriction(s): Conditionally Required. Record this element when the type of cyber event is recorded as "Other" (i.e.
<CyberEventIndicatorsTypeCode> contains the value "11" code); otherwise, do not record this element.
Value Restriction(s): The value provided must adhere to the following requirements: 50 characters or less
Remarks: The batch submission will be accepted with warnings if any of the following conditions are true:
The element is not recorded or does not contain a value and the
<CyberEventIndicatorsTypeCode> is equal to “11” Other.
The element is recorded with a value and the <CyberEventIndicatorsTypeCode> is not equal
to “11” Other.
Example: <fc2:CyberEventTypeOtherText>Other description</fc2:CyberEventTypeOtherText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: CyberEventIndicators
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements: 4000 characters or less; must be in the
following format based on these specific types of cyber events:
Command and Control/Suspicious IP Addresses: If the IP address is IPv4, use a variation of the
format nnn.nnn.nnn.nnn (n = number) with periods between the segments. First set of
numbers must be values between 1-255 (inclusive); second, third and fourth set of numbers
must be values between 0-255 (inclusive). If the IP address is IPv6, use a variation of the
format cccc:cccc:cccc:cccc:cccc:cccc:cccc:cccc (c = character, IPv6 is alphanumeric in some
segments) with colons between the segments.
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Please refer to Attachment C for additional information regarding the above item(s).
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
If multiple product/instrument types and/or payment mechanisms were involved in the suspicious
activity, record a separate instance of this element to identify each one that applies. The following table
describes the min/max number of occurrences this element may be recorded for item 45 (product type)
and item 46 (instrument type/payment mechanism):
Sub-types associated with the following types: min-max
Total 0-31
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Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Assets
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Item 45. Product type (AssetTypeID=5)
Code Description
2 Bonds/Notes
3 Commercial mortgage
4 Commercial paper
5 Credit card
6 Debit card
46 Deposit Account
7 Forex transactions
8 Futures/Options on futures
9 Hedge fund
11 Home equity line of credit
10 Home equity loan
12 Insurance/Annuity products
47 Microcap securities
13 Mutual fund
14 Options on securities
16 Prepaid access
17 Residential mortgage
18 Security futures products
19 Stocks
20 Swap, hybrid, or other derivative
30 Other
31 Bank/Cashier's check
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Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
The element contains a value that is not appropriate for the type of asset recorded.
The element contains a value that has already been recorded for the Activity.
Example: <fc2:AssetSubtypeID>2</fc2:AssetSubtypeID>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: Assets
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Code Description
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
Example: <fc2:AssetTypeID>5</fc2:AssetTypeID>
Please refer to Attachment C for additional information regarding the above item(s).
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Please refer to Attachment C for additional information regarding the above item(s).
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
No more than 99 occurrences of each asset attribute type mentioned above may be recorded for the
FinCEN SAR:
Attribute types min-max
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Total 0-396
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: AssetsAttribute
Element Restriction(s): Required. This element must be recorded if the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Commodity type description: 50 characters or less
Instrument/Product description: 50 characters or less
Market where traded: 3-5 letter code for the market where a recorded commodity was
traded. Use only the ISO 10383 Exchange/Market Identifier Codes (MIC) found at
http://www.iso15022.org/MIC/homepageMIC.htm.
CUSIP Number: 12 characters or less to identify the CUSIP number of a recorded securities
product (such as stocks and bonds) involved in the suspicious.
Remarks: The batch submission will be accepted with warnings if any of the following conditions are true:
The element is not recorded or the element is recorded but with no value.
The value recorded is not valid based on the type of asset attribute (see Value Restrictions for
format requirements).
Example: <fc2:AssetAttributeDescriptionText>Commodity type description</fc2:AssetAttributeDescriptionText>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) n/a
Parent Element: AssetsAttribute
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2 Commodity type
3 Product/Instrument type
4 Market where traded
1 CUSIP number
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded.
The element is recorded but without a value (i.e. the value is null).
The element contains a value not equal to one of the approved codes listed above.
Example: <fc2:AssetAttributeTypeID>2</fc2:AssetAttributeTypeID>
Please refer to Attachment C for additional information regarding the above item(s).
Attribute(s) The following attributes must be recorded for this element:
Name Description
SeqNum The value recorded for this attribute must be numeric and unique. It may contain
any numeric value up to 19 characters in length.
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For example, if the narrative text is 5,000 characters in length, there should be two instances of the
ActivityNarrativeInformation element block, where the first instance contains
ActivityNarrativeSequenceNumber “>1<” followed by the first 4,000 characters of the narrative
description in the ActivityNarrativeText element; in order to record the remaining 1,000 characters of
the narrative description, a second instance of the ActivityNarrativeInformation element block should be
recorded where the ActivityNarrativeSequenceNumber is “>2<” followed by the remaining 1,000
characters of the narrative description in the ActivityNarrativeText element.
Attribute(s) n/a
Parent Element: ActivityNarrativeInformation
Element Restriction(s): Required. This element must be recorded when the parent element is recorded.
Value Restriction(s): The value provided must adhere to the following requirements:
Code Description
Remarks: The batch submission will be rejected if any of the following conditions are true:
The element is not recorded or does not contain a value.
The value recorded is not equal to a valid code.
The element contains a value that has already been recorded for the Activity.
Example: <fc2:ActivityNarrativeSequenceNumber>1</fc2:ActivityNarrativeSequenceNumber>
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Element name 35 37 30 8 18 19 34 46 33 41
<Party SeqNum=""> ● ● ● ● ● ● ● ●
<ActivityPartyTypeCode/> ● ● ● ● ● ● ● ●
<AdmissionConfessionNoIndicator/> ●
<AdmissionConfessionYesIndicator/> ●
<AllCriticalSubjectInformationUnavailableIndicator/> ●
<BirthDateUnknownIndicator/> ●
<BothPurchaserSenderPayeeReceiveIndicator/> ●
<ContactDateText/> ●
<FemaleGenderIndicator/> ●
<IndividualBirthDateText/> ●
<LossToFinancialAmountText/> ●
<MaleGenderIndicator/> ●
<NoBranchActivityInvolvedIndicator/> ●
<NoKnownAccountInvolvedIndicator/> ●
<NonUSFinancialInstitutionIndicator/>
<PartyAsEntityOrganizationIndicator/> ●
<PayeeReceiverIndicator/> ●
<PayLocationIndicator/> ●
<PrimaryRegulatorTypeCode/> ● ●
<PurchaserSenderIndicator/> ●
<SellingLocationIndicator/> ●
<SellingPayingLocationIndicator/> ●
<UnknownGenderIndicator/> ●
<PartyName SeqNum=""> ● ● ● ● ● ● ● ●
<EntityLastNameUnknownIndicator/> ● ●
<FirstNameUnknownIndicator/> ●
<PartyNameTypeCode/> ● ● ● ● ● ● ● ●
<RawEntityIndividualLastName/> ●
<RawIndividualFirstName/> ●
<RawIndividualMiddleName/> ●
<RawIndividualNameSuffixText/> ●
<RawPartyFullName/> ● ● ● ● ● ● ● ●
</PartyName> ● ● ● ● ● ● ● ●
<Address SeqNum=""> ● ● ● ●
<CityUnknownIndicator/> ● ●
<CountryCodeUnknownIndicator/> ● ●
<RawCityText/> ● ● ● ●
<RawCountryCodeText/> ● ● ● ●
<RawStateCodeText/> ● ● ● ●
<RawStreetAddress1Text/> ● ● ● ●
<RawZIPCode/> ● ● ● ●
<StateCodeUnknownIndicator/> ●
<StreetAddressUnknownIndicator/> ● ●
<ZIPCodeUnknownIndicator/> ● ●
</Address> ● ● ● ●
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Element name 35 37 30 8 18 19 34 46 33 41
<PhoneNumber SeqNum=""> ● ● ● ●
<PhoneNumberExtensionText/> ● ● ●
<PhoneNumberText/> ● ● ● ●
<PhoneNumberTypeCode/> ●
</PhoneNumber> ● ● ● ●
<PartyIdentification SeqNum=""> ● ● ● ●
<IdentificationPresentUnknownIndicator/> ●
<OtherIssuerCountryText/> ●
<OtherIssuerStateText/> ●
<OtherPartyIdentificationTypeText/> ●
<PartyIdentificationNumberText/> ● ● ● ●
<PartyIdentificationTypeCode/> ● ● ● ●
<TINUnknownIndicator/> ● ●
</PartyIdentification> ● ● ● ●
<OrganizationClassificationTypeSubtype SeqNum=""> ● ●
<OrganizationSubtypeID/> ● ●
<OrganizationTypeID/> ● ●
<OtherOrganizationSubTypeText/> ● ●
<OtherOrganizationTypeText/> ● ●
</OrganizationClassificationTypeSubtype> ● ●
<PartyOccupationBusiness SeqNum=""> ●
<NAICSCode/> ●
<OccupationBusinessText/> ●
</PartyOccupationBusiness> ●
<ElectronicAddress SeqNum=""> ●
<ElectronicAddressText/> ●
<ElectronicAddressTypeCode/> ●
</ElectronicAddress> ●
<PartyAssociation SeqNum=""> ● ●
<AccountantIndicator/> ●
<ActionTakenDateText/> ●
<AgentIndicator/> ●
<AppraiserIndicator/> ●
<AttorneyIndicator/> ●
<BorrowerIndicator/> ●
<CustomerIndicator/> ●
<DirectorIndicator/> ●
<EmployeeIndicator/> ●
<NoRelationshipToInstitutionIndicator/> ●
<OfficerIndicator/> ●
<OtherPartyAssociationTypeText/> ●
<OtherRelationshipIndicator/> ●
<OwnerShareholderIndicator/> ●
<RelationshipContinuesIndicator/> ●
<ResignedIndicator/> ●
<SubjectRelationshipFinancialInstitutionTINText/> ●
<SuspendedBarredIndicator/> ●
<TerminatedIndicator/> ●
<Party SeqNum=""> ● ●
<ActivityPartyTypeCode/> ● ●
<PayLocationIndicator/> ● ●
<SellingLocationIndicator/> ● ●
<SellingPayingLocationIndicator/> ● ●
<Address SeqNum=""> ● ●
<RawCityText/> ● ●
<RawCountryCodeText/> ● ●
<RawStateCodeText/> ● ●
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Element name 35 37 30 8 18 19 34 46 33 41
<RawStreetAddress1Text/> ● ●
<RawZIPCode/> ● ●
</Address> ● ●
<PartyIdentification SeqNum=""> ● ●
<PartyIdentificationNumberText/> ● ●
<PartyIdentificationTypeCode/> ● ●
</PartyIdentification> ● ●
</Party> ● ●
</PartyAssociation> ● ●
<PartyAccountAssociation SeqNum=""> ●
<PartyAccountAssociationTypeCode/> ●
<Party SeqNum=""> ● ●
<ActivityPartyTypeCode/> ● ●
<NonUSFinancialInstitutionIndicator/> ● ●
<PartyIdentification SeqNum=""> ● ●
<PartyIdentificationNumberText/> ● ●
<PartyIdentificationTypeCode/> ● ●
</PartyIdentification> ● ●
<Account SeqNum=""> ● ●
<AccountNumberText/> ● ●
<PartyAccountAssociation SeqNum=""> ● ●
<AccountClosedIndicator/> ● ●
<PartyAccountAssociationTypeCode/> ● ●
</PartyAccountAssociation> ● ●
</Account> ● ●
</Party> ● ●
</PartyAccountAssociation> ●
</Party> ● ● ● ● ● ● ● ●
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<fc2:IdentificationPresentUnknownIndicator>Y</fc2:IdentificationPresentUnknownIndicator>
<fc2:OtherIssuerCountryText>US</fc2:OtherIssuerCountryText>
<fc2:OtherIssuerStateText>CA</fc2:OtherIssuerStateText>
<fc2:OtherPartyIdentificationTypeText>Student ID</fc2:OtherPartyIdentificationTypeText>
<fc2:PartyIdentificationNumberText>660623559</fc2:PartyIdentificationNumberText>
<fc2:PartyIdentificationTypeCode>999</fc2:PartyIdentificationTypeCode>
</fc2:PartyIdentification>
<fc2:PartyIdentification SeqNum="69">
<fc2:TINUnknownIndicator>Y</fc2:TINUnknownIndicator>
</fc2:PartyIdentification>
<fc2:PartyOccupationBusiness SeqNum="70">
<fc2:NAICSCode>7548</fc2:NAICSCode>
<fc2:OccupationBusinessText>Mechanic</fc2:OccupationBusinessText>
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<fc2:SubjectRelationshipFinancialInstitutionTINText>458789856</fc2:SubjectRelationshipFinancialInsti
tutionTINText>
</fc2:PartyAssociation>
<fc2:PartyAccountAssociation SeqNum="74">
<fc2:PartyAccountAssociationTypeCode>7</fc2:PartyAccountAssociationTypeCode>
<fc2:Party SeqNum="75">
<fc2:ActivityPartyTypeCode>41</fc2:ActivityPartyTypeCode>
…
</fc2:Party>
</fc2:PartyAccountAssociation>
</fc2:Party>
<fc2:Party SeqNum="75">
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Description: XML declaration/prolog. This is the XML declaration which specifies the XML version and character
encoding used in the file.
Attribute(s): version. The version number of the XML. The value recorded will be “1.0”
encoding. The character encoding used for the XML. The value recorded will be “UTF-8”
Parent Element: n/a
Element Restriction(s) This declaration will always be recorded on the first line of the file.
Remarks: none
6.1.2. EFilingBatchXML
The <EFilingBatchXML> element is the first element recorded in the file and is considered the root element.
Description: Batch acknowledgement (header). This is the container for the contents of the batch acknowledgement
file.
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Attribute(s): SeqNum (this is a sequential number assigned by FinCEN to identify the corresponding element in the
associated batch file)
StatusCode (this will have a value of “A” to indicate “Acknowledged”)
Parent Element: n/a (this is the root element in the acknowledgment file)
Element Restriction(s) This element will always be recorded.
6.1.3. EFilingSubmissionXML
The <EFilingSubmissionXML> element directly follows the <EFilingBatchXML> root element. This element is for
FinCEN use only.
Description: Submission acknowledgement (header). This is the container for all FinCEN SAR <Activity> elements
recorded in the associated batch submission.
6.1.4. EFilingActivityXML
Each <EFilingActivityXML> element in the batch acknowledgement file corresponds with each FinCEN SAR <Activity>
element recorded in the original batch submission along with the sequence number (SeqNum) attribute value.
Description: Activity acknowledgement (header). This is the container for acknowledgement information for each
FinCEN SAR <Activity> element recorded in the associated batch submission.
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Remarks: none
Example: <EFilingActivityXML SeqNum="1">
<BSAID>31000055053784</BSAID>
<EFilingActivityErrorXML SeqNum="1"/>
</EFilingActivityXML>
Description: Activity acknowledgement BSA Identifier (text). This element identifies the BSA Identifier (BSA ID)
assigned by FinCEN to the FinCEN SAR document.
Attribute(s): n/a
6.1.5. EFilingActivityErrorXML
There will be at least one <EFilingActivityErrorXML> element for each <EFilingActivityXML> element in the batch
acknowledgement file.
Description: Activity acknowledgement error (header). This is the container for error information generated during
processing of the associated batch submission related to the FinCEN SAR activity.
Remarks: If there are no errors identified for the FinCEN SAR activity, then the <EFilingActivityErrorXML> element
will be recorded with a self-closing tag (e.g. <EFilingActivityErrorXML SeqNum=”1”/>) and this element
will not be recorded.
Example: <EFilingActivityErrorXML SeqNum="1">
<ErrorContextText>EFilingBatchXML/Activity[1]/Party[25]/PartyIdentification[49]/PartyIdentifi
cationNumberText</ErrorContextText>
<ErrorElementNameText>PartyIdentificationNumberText</ErrorElementNameText>
<ErrorLevelText>WARN</ErrorLevelText>
<ErrorText>The value recorded for the EIN or SSN/ITIN is an invalid number
string.</ErrorText>
<ErrorTypeCode>C21</ErrorTypeCode>
</EFilingActivityErrorXML>
<EFilingActivityErrorXML SeqNum="2">
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<ErrorContextText>EFilingBatchXML/Activity[1]/Party[78]/PartyName[84]/RawIndividualFirstN
ame</ErrorContextText>
<ErrorElementNameText>RawIndividualFirstName</ErrorElementNameText>
<ErrorLevelText>WARN</ErrorLevelText>
<ErrorText>The element is not recorded or does not contain a value for an individual Subject
and unknown is not indicated.</ErrorText>
<ErrorTypeCode>C4</ErrorTypeCode>
</EFilingActivityErrorXML>
Description: Acknowledgement error type (text). This element identifies the element location (within the associated
batch submission) that triggered the error by identifying the name and sequence number of the
element’s <Parent> element.
Attribute(s): n/a
Description: Element acknowledgement error association (text). This element identifies the element name from the
associated batch submission that triggered the error.
Attribute(s): n/a
Parent Element: EFilingActivityErrorXML
Value Restriction(s): 1-512 characters
Remarks: If there are no errors identified for the FinCEN SAR activity, then the <EFilingActivityErrorXML> element
will be recorded with a self-closing tag (e.g. <EFilingActivityErrorXML SeqNum=”1”/>) and this element
will not be recorded.
Example: <ErrorElementNameText>PartyIdentificationNumberText</ErrorElementNameText>
Description: Acknowledgement error severity level (text). This element identifies the level of severity associated with
the error.
Attribute(s): n/a
Example: <ErrorLevelText>WARN</ErrorLevelText>
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Description: Acknowledgement error description (text). This element identifies the description of the error.
Attribute(s): n/a
Description: Acknowledgement error type (code). This element identifies the code associated with the error.
Attribute(s): n/a
Parent Element: EFilingActivityErrorXML
Value Restriction(s): 1-50 characters
Remarks: If there are no errors identified for the FinCEN SAR activity, then the <EFilingActivityErrorXML> element
will be recorded with a self-closing tag (e.g. <EFilingActivityErrorXML SeqNum=”1”/>) and this element
will not be recorded.
Example: <ErrorTypeCode>C4</ErrorTypeCode>
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</EFilingSubmissionXML>
</EFilingBatchXML>
Notes: The sample above consists of three (3) FinCEN SAR activities based on the original FinCEN SAR batch submission:
Each FinCEN SAR from the original batch submission is associated with a <EFilingActivityXML> element
Each FinCEN SAR receives a unique BSA Identifier (BSA ID)
FinCEN SAR (BSA ID: 31000055053784) contains two errors (C21 & C4)
FinCEN SAR (BSA ID: 31000055053785) contains no errors
FinCEN SAR (BSA ID: 31000055053786) contains no errors
Error Level
Fatal
Batch rejection
These errors are related to the batch format and must be resolved before attempting to resubmit the batch.
Primary Warning
Batch acceptance with warning(s) classified as primary data errors
These errors violate electronic filing requirements or report instructions and so degrade FinCEN SAR data quality that they must be
corrected (along with warning errors) as a correction/amendment Error codes marked with an asterisk (*) are primary warnings.
Warning
Batch acceptance with warning(s) classified as secondary data errors.
These errors that violate electronic filing requirements or report instructions but have a lesser impact on FinCEN SAR data quality.
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D5 The element is not recorded or does Warning OtherOrganizationTypeText 51z. Institution Type Other
not contain a value and the Description
institution type is equal to Other.
D6 The element is recorded with a value Warning OtherOrganizationTypeText 51z. Institution Type Other
but the institution type is not equal Description
to Other.
D7 The element is not recorded. Fatal PrimaryRegulatorTypeCode 52a-i. Primary Federal
Regulator
D8 The element is recorded but with no Fatal PrimaryRegulatorTypeCode 52a-i. Primary Federal
value (i.e. the value is null). Regulator
D9 The element contains an invalid code. Fatal PrimaryRegulatorTypeCode 52a-i. Primary Federal
Regulator
D10 The element is not recorded or does Fatal OrganizationSubtypeID 53a-c,z
not contain a value (i.e. the value is 54a-k,z. Institution
null) and the institution type is equal Subtype: Gaming
to Casino/Card club or Securities and Institution,
Futures. Institution Subtype:
Securities/Futures
Institution
D11 The element contains an invalid code. Fatal OrganizationSubtypeID 53a-c,z
54a-k,z. Institution
Subtype: Gaming
Institution,
Institution Subtype:
Securities/Futures
Institution
D12 The element contains a value but the Fatal OrganizationSubtypeID 53a-c,z
institution type is not equal to 54a-k,z. Institution
Casino/Card club or Securities and Subtype: Gaming
Futures. Institution,
Institution Subtype:
Securities/Futures
Institution
D14 The value recorded conflicts with the Fatal OrganizationSubtypeID 53a-c,z
institution type recorded (e.g. State 54a-k,z. Institution
Casino recorded for Securities and Subtype: Gaming
Futures institution) Institution,
Institution Subtype:
Securities/Futures
Institution
D15 The element is not recorded or does Warning OtherOrganizationSubTypeTe 53z
not contain a value and the xt 54z. Institution Subtype
institution subtype is equal to Other. Other: Gaming Institution
Description
Institution Subtype Other:
Securities/Futures
Institution Description
D16 The element is recorded with a value Warning OtherOrganizationSubTypeTe 53z
but the institution subtype is not xt 54z. Institution Subtype
equal to Other. Other: Gaming Institution
Description
Institution Subtype Other:
Securities/Futures
Institution Description
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D41 The element is not recorded for the Warning Address 69, 71-74. Address
Branch and
<NoBranchActivityInvolvedIndicator>
does not contain a "Y" value.
D44 The element contains an invalid state Fatal RawStateCodeText 72. Address: State
code.
D45 The element contains a value and the Warning RawStateCodeText 72. Address: State
country is not US, CA, MX, or a U.S.
Territory.
D46 The element is not recorded or does Warning RawStateCodeText 72. Address: State
not contain a value when the country
is a U.S. Territory.
D47 State code and country code Warning RawCountryCodeText 72, 74. Address: State,
mismatch when U.S. Territory is RawStateCodeText Country
recorded.
D49 The element contains an invalid Fatal RawCountryCodeText 74. Address: Country
country code.
D50 The element is not recorded or does Warning RawCountryCodeText 74. Address: Country
not contain a value.
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These errors can occur at the FinCEN SAR document level associated with the Part V Attachment & Narrative
Information:
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G19 The value recorded for the element Warning Transmitter Telephone NA
contains non-numeric characters Number
G20 The element is not recorded or does Warning Transmitter Telephone NA
not contain a value (i.e. the value is Number
null).
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Correction Requirements:
Filers should immediately correct and resubmit a batch file rejected for fatal errors when notified by FinCEN the batch
file was not accepted.
When an accepted batch file contains FinCEN SARs with primary warning errors, those FinCEN SARs must be re-filed
as a corrected report with the primary errors and any secondary errors corrected. FinCEN SARs that contain only
secondary errors need not be corrected. FinCEN requires that filers prevent all reported errors in their future filings.
FinCEN recommends that data error corrections be made no later than 30 days after receiving error notifications.
Furthermore, FinCEN recommends that filers remedy any systemic problems in their electronic submissions within 30
days of receiving error notifications. If technical issues prevent filers from implementing corrections within these time
frames, filers should notify FinCEN by writing to:
Financial Crimes Enforcement Network
Office of Domestic Liaison
Data Quality Assessments
P.O. Box 39
Vienna, VA 22183
This correspondence should explain the technical issues involved that prevent meeting the time frame, provide an
estimate of when the issues will be resolved, and include a contact name and telephone number.
Correction Procedures:
FinCEN SAR batch files are rejected when they contain fatal format errors. Filers must correct all fatal errors identified
in the batch file and resubmit the batch file to BSA E-Filing. Because they were not accepted by FinCEN, initial report
FinCEN SARs in the re-submitted batch file are still initial reports. Do not identify FinCEN SARs from a rejected batch
file as Amended reports unless they originally were filed as Amended reports.
If errors involve accepted with warning errors in the FinCEN SARs of an accepted batch file, filers should correct all
errors and file amended reports on the affected FinCEN SARs using the following procedures:
Make the corrections to all errors in the FinCEN SARs in the accepted batch file.
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Record “Y” in the <CorrectsAmendsPriorReportIndicator> element under the <Activity Association> element
in each FinCEN SAR to be corrected.
Record in the <EFilingPriorDocumentNumber> element under the <Activity> element the BSA Identifier
(from the FinCEN SAR Acknowledgement) that was assigned to the FinCEN SAR being corrected.
Ensure that the <FilingDateText> element contains a new date.
Complete all other data in the FinCEN SAR in their entirety.
Retransmit the corrected FinCEN SAR in a new batch file. Do not re-transmit the original batch file because
this will cause duplicate database entries on any FinCEN SARs that were not corrected.
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structure, for purposes that are consistent with the Bank Secrecy Act, as determined by regulation or
guidance.
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4. Additional Filing Instructions for Banks: In addition to the above requirements, a bank (as defined in 31 CFR §
1010.100) must file a FinCEN SAR for activity (as required by 31 CFR § 1020.320 and 12 CFR §§ 21.11, 163.180, 208.62,
353.3, and 748.1) involving:
Insider abuse involving any amount. Whenever the bank detects any known or suspected Federal criminal
violations, or pattern of criminal violations, committed or attempted against the financial institution or
involving a transaction or transactions conducted through the financial institution, where the bank believes
that it was either an actual or potential victim of a criminal violation, or series of criminal violations, or that
the bank was used to facilitate a criminal transaction, and the bank has a substantial basis for identifying
one of its directors, officers, employees, agents or other institution- affiliated parties as having committed or
aided in the commission of a criminal act regardless of the amount involved in the violation.
Violations aggregating $5,000 or more where a suspect can be identified. Whenever the bank detects
any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted
against the bank or involving a transaction or transactions conducted through the bank and involving or
aggregating $5,000 or more in funds or other assets, where the bank believes that it was either an actual or
potential victim of a criminal violation, or series of criminal violations, or that the bank was used to facilitate a
criminal transaction, and the bank has a substantial basis for identifying a possible suspect or group of
suspects. If it is determined prior to filing this report that the identified suspect or group of suspects has used
an “alias,” then information regarding the true identity of the suspect or group of suspects, as well as alias
identifiers, such as drivers’ licenses or social security numbers, addresses and telephone numbers, must be
reported.
Violations aggregating $25,000 or more regardless of a potential suspect. Whenever the bank detects
any known or suspected Federal criminal violation, or pattern of criminal violations, committed or attempted
against the bank or involving a transaction or transactions conducted through the bank and involving or
aggregating $25,000 or more in funds or other assets, where the bank believes that it was either an actual or
potential victim of a criminal violation, or series of criminal violations, or that the bank was used to facilitate
a criminal transaction, even though there is no substantial basis for identifying a possible suspect or group of
suspects.
5. Voluntary FinCEN SAR Filings: Financial institutions may also file with FinCEN a report of any suspicious
transaction that it believes is relevant to the possible violation of any law or regulation but whose reporting is not
required by 31 CFR Chapter X. A voluntary filing does not relieve a financial institution from the responsibility of
complying with any other reporting requirements imposed by the SEC, the CFTC, a self-regulatory organization (SRO)
(as defined in section 3(a)(26) of the Securities Exchange Act of 1934, 15 U.S.C. 78c (a)(26)), or any Registered Futures
Association (RFA) or Registered Entity (RE) (as these terms are defined in the Commodity Exchange Act, 7 U.S.C. 21
and 7 U.S.C. 1a(29)).
6. Exceptions: The following are exceptions to the FinCEN SAR reporting requirements:
A bank, casino, broker or dealer in securities (BD), futures commission merchant (FCM), or introducing
broker in commodities (IB-C) is not required to file a FinCEN SAR for a robbery or burglary committed or
attempted against the financial institution when the robbery or burglary is reported to appropriate law
enforcement authorities.
A FinCEN SAR is not required to be filed for lost, missing, counterfeit, or stolen securities that are reported
pursuant to the requirements of 17 CFR § 240.17f-1.
A BD is not required to file a FinCEN SAR on violations of any of the Federal securities laws or the rules of a
SRO by the BD or any of its officers, directors, employees or other registered representatives, other than a
violation of 17 CFR § 240.17a-8 or 17 CFR § 405.4, so long as such violation is appropriately reported to the
SEC or an SRO.
An FCM or an IB-C, or any of its officers, directors, employees or associated persons, is not required to file a
FinCEN SAR for a violation of the Commodity Exchange Act (7 U.S.C. 1 et seq.), the regulations of the CFTC (17
CFR Chapter 1), or the rules of any RFA or RE (as those terms are defined in the Commodity Exchange Act, 7
U.S.C. 21 and 7 U.S.C. 1a(29)), as long as such violation is appropriately reported to the CFTC, an RFA, or RE.
This exception does not apply to violations of 17 CFR § 42.2.
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An insurance company is not required to report the submission to it of false or fraudulent information to
obtain a policy or make a claim, unless the company has reason to believe that that the false or fraudulent
submission relates to money laundering or terrorist financing.
An issuer of money orders or traveler’s checks is not required to report a transaction or pattern of
transactions when the transactions were identified through a review of clearance records or other similar
records and the transaction amount or aggregated transaction amount involves funds or other assets of less
than $5,000.
7. Additional Reporting: The Bank Secrecy Act requires financial institutions to file a Currency Transaction Report
(CTR) in accordance with the Department of the Treasury’s implementing regulations (31 CFR § 1010.310) whenever a
currency transaction exceeds $10,000. If a currency transaction exceeds $10,000 and is otherwise reportable as
suspicious activity, the institution must file both a CTR (reporting the currency transaction) and a FinCEN SAR
(reporting the suspicious activity). If a currency transaction is $10,000 or less and is otherwise reportable as a
suspicious activity, the institution should only file a FinCEN SAR. Appropriate records must be maintained in each
case. Residential Mortgage Lenders and Originators are required to file Form 8300, Report of Cash Payments Over
$10,000 Received in a Trade or Business, instead of a CTR.
NOTE: Throughout these instructions the phrases “check box” and “select option” or similar wording is used
to denote checking an appropriate box or selecting a drop-down list option in certain data items on the
discrete FinCEN SAR. These are deemed equivalent to instructions in the XML Filing Requirements to enter
appropriate codes or responses in the same data items in XML-format transmission files. For example, the
requirement to check box 1 “Initial report” in the discrete FinCEN SAR is the equivalent of entering “Y” in
XML element <InitialReportIndicator>.
NOTE: Throughout these instructions there are requirements to complete items multiple times in a discrete
FinCEN SAR if the filer has multiple entries for that item. This is deemed equivalent to completing multiple
XML elements for that item in the XML Filing Requirements. For example, these instructions direct filers to
complete multiple Item 6 “Alternate name” fields if the filer has knowledge of multiple alternate names for a
subject. This is equivalent to a batch filer recording multiple XML <PartyName> elements and appropriate
sub-elements for the same subject.
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3. Corrected/Amended Reports: A corrected report on a previously-filed FinCEN SAR or prior FinCEN SAR
version must be filed whenever errors are discovered in the data reported in that FinCEN SAR. An amended
report must be filed on a previously-filed FinCEN SAR or prior FinCEN SAR versions whenever new data
about a reported suspicious activity is discovered and circumstances will not justify filing a continuing report
(see General Instruction 4). Both corrected and amended reports must be completed in their entirety, with
the necessary corrections or amendments made to the data. In both cases box 1b “Correct/Amend prior
report” must be checked. If known, the prior report’s BSA Identifier (BSA ID) must be entered in field 1e. If
the prior report’s BSA ID is unknown, field 1e should be zero-filled. All corrections or amendments must be
described completely at the beginning of the Part V Suspicious Activity Information – Narrative section.
If a FinCEN SAR is filed to correct or amend a prior FinCEN SAR version, the FinCEN SAR must be completed
in its entirety. This includes FinCEN SAR items that apply to the suspicious activity but were not present on
the prior FinCEN SAR version. FinCEN SAR items not on the prior FinCEN SAR version need not be described
in the narrative. BSA IDs are provided in acknowledgement records sent to member financial institutions by
the BSA E-Filing System.
4. Continuing Reports: A continuing report may be filed on suspicious activity that continues after an initial
FinCEN SAR is filed. Continuing reports should be filed on successive 90-day review periods until the
suspicious activity ceases, but may be filed more frequently if circumstances warrant that. Filers have up to 30
days following the end of a review period to file the continuing report for a total of 120 days of review and
filing deadline. Continuing reports must be completed in their entirety, including the information about all
subjects involved in the suspicious activity and all financial institutions where the activity occurred. The
continuing report Part V narrative should include all details of the suspicious activity for the 90-day period
encompassed by the report, and only such data from prior reports as is necessary to understand the activity.
Do not reproduce the narratives from prior reports in the continuing report. Provide both the dollar amount
involved in the suspicious activity for the 90-day period in Item 29 and the cumulative dollar amount for the
current and prior related reports in Item 31. If continuing losses are involved for a financial institution
recorded in Part III, record the 90-day loss in Item 67 and the cumulative loss in Part V.
5. Joint Report: A FinCEN SAR may be jointly filed when two or more distinct financial institutions recorded in
Part III “Information about Financial Institution Where Activity Occurred” collaborate in filing a single FinCEN
SAR on suspicious activity involving all of the collaborating financial institutions. Financial institutions are
“distinct” for this purpose when they are different legal entities; a financial institution is not distinct from its
own branches. Joint filing of a single FinCEN SAR is prohibited when any of the Part I “Subject Information”
subjects of the would-be jointly filed FinCEN SAR have a box in Item 24 checked that identifies the subject as
a director, employee, officer, or owner/controlling shareholder of the filing institution or a would-be joint
filer. In that case separate FinCEN SARs must be filed by each institution. To be a jointly-filed FinCEN SAR,
box 1d “Joint report” must be checked. In addition, the filing institution listed in Part IV “Filing Institution
Contact Information” must identify in Part V “Suspicious Activity Information – Narrative” which Part III
“Information about Financial Institution Where Activity Occurred” institutions are joint filers. The filing
institution must include joint filer contact information in Part V, along with a description of the information
provided by each joint filer. Record joint filer information in Part III Items 51 through 65 and joint filer branch
information in Part III Items 68 through 74. Filing a joint FinCEN SAR does not relieve joint filers of the
responsibility to report information about the suspicious activity that was not included in the joint filing. A
filing institution cannot designate another institution as a joint filer unless the designated joint filer is aware
of and approves the FinCEN SAR filing in its entirety. A filer that designates another institution as a joint filer
without gaining that institution’s agreement to the joint filing and approval of the contents of the joint filing
may have committed a willful violation of the Bank Secrecy Act, if the improper designation leads to the
disclosure of the FinCEN SAR filing to a person not entitled to information about the filing. Both filers and
joint filers are required to keep copies of the FinCEN SAR and their own supporting documentation for five (5)
years after the date of filing.
6. Supporting Documentation: Filers can include a single Microsoft Excel compatible comma separated
values (CSV) file with no more than one megabyte of data as an attachment to the FinCEN SAR. The contents
of this file must be described in Part V. This file would be most suitable for documenting transaction records
that are too numerous to record in Part V. Do not include any other supporting documentation with the
FinCEN SAR. Instead, describe in Part V other supporting documentation not included in the file. Filers must
retain all supporting documentation or a business record equivalent for five (5) years from the date of the
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report (31 CFR § 1010.430). All supporting documentation (such as copies of instruments; receipts; sale,
transaction or clearing records; photographs; and surveillance audio or video recordings) must be made
available to appropriate authorities upon request. See Attachment D for information on attaching comma
separated (.CSV) files to a FinCEN SAR filing.
7. Addresses: For addresses in the U.S., Canada, or Mexico enter the permanent street address, city, two or
three letter state/territory/province code, ZIP Code or foreign postal code, and two-letter country code or
U.S. Territory code for the individual or entity recorded in Part I, Part III, or Part IV. Provide the apartment
number or suite number, if known, following the street address. A non-location address such as a post office
box or rural route number should be used only if no other street address information is available. ZIP Codes
must be five or nine digits. ZIP Codes and foreign postal codes must be entered without formatting or
special characters such as spaces or hyphens. For example, the ZIP Code 12345-6120 would be entered as
123456120. The foreign postal code HKW 702 would be entered HKW702. When an address is in a U.S.
Territory the territory code must be entered in the state and country fields. For other foreign addresses enter
the street address, city, postal code, and two letter country code or address equivalents. Leave the state item
blank, including the “Unknown box” when provided. If a foreign address contains address information that
does not conform to the FinCEN SAR address format, record equivalent address information in the FinCEN
SAR address items (except state) and ignore non-conforming data. The complete foreign address should be
recorded in the FinCEN SAR’s Part V narrative section. Complete any address item that is known, even if the
entire address is not known. No abbreviations are permitted in city names, which must be completely spelled
out. A U.S. city name must match the city name used by the U.S. Postal Service for the associated state and
ZIP Code. U.S. State codes must conform to the codes used by the United States Postal Service as
documented in ISO 3166-2:US. Canadian province and territory codes must conform to the codes used by
the Canadian Post Corporation as documented in ISO 3166-2:CA. Mexican state and federal district codes
must conform to ISO 3166-2:MX. Country codes and U.S. Territory Codes must conform to the codes
documented in ISO 3166-2. The ISO lists are available through the International Standards Organization.
NOTE: The ISO 3166-2 country list contains the code “UM” that stands for the United State Minor Outlying
Islands. Using “UM” in country fields is prohibited. These islands are uninhabited. As such they have no
addresses.
8. Telephone Numbers: Record all telephone numbers, both foreign and domestic, as a single number string
without formatting or special characters such as parentheses or hyphens. For example, a number in the
format (NNN) NNN-NNNN would be recorded as NNNNNNNNNN. Indicate the type of telephone number
provided (home, work, mobile, or fax) by checking the appropriate box. Provide the telephone extension
number if known. Telephone numbers that are part of the North American Numbering Plan used by the U.S.,
Canada, many Caribbean countries, and current/former U.S. Pacific island protectorates must consist of an
area code and seven-digit telephone number. Other foreign telephone numbers should include the country
number code. If only a partial telephone number is known record that number in the phone number item
and explain in Part V that the entry is a partial number.
9. Identifying Numbers: Enter all identifying numbers as a single text string without formatting or special
characters such as hyphens or periods. An identifying number in the format NNN-NN-NNNN would be
entered as NNNNNNNNN. Such numbers include account numbers, alien registration numbers, CRD,
CUSIP®, driver’s license numbers, state identifications, EINs, IARDs ITINs, passport numbers, RSSDs, SEC IDs,
and SSNs.
10. Monetary Amounts: Record all monetary amounts in U.S. Dollars rounded up to the next whole dollar. The
amount $5,265.25 would be rounded up to $5,266. If the amount involves a foreign currency, record the
currency name, amount, and country of origin in Part V. When converting a foreign currency to U.S. Dollars
use an exchange rate for the date or dates the foreign currency was involved in the suspicious activity.
11. Prohibited Words and Phrases: Do not use the following words or variations of these words in text fields,
other than in Part V:
a. AKA
b. COMPUTER GENERATED
c. CUSTOMER
d. DBA
e. NON CUSTOMER
f. NONE
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g. NOT APPLICABLE
h. OTHER
i. SAME
j. SAME AS ABOVE
k. SEE ABOVE
l. SEE NARRATIVE
m. SIGNATURE CARD
n. T/A
o. UNKNOWN
p. VARIOUS
q. XX
12. Name Editing Instructions: Because many names do not consist of a single first name, middle name, and
last name, care must be taken to ensure these names are entered properly in the BSA FinCEN SAR. This is
especially important when there are separate fields for the last name, first name, and middle name. Some
names have multiple surnames (family names) or multiple given names that do not include a middle name.
Others may not be written in [first name] [middle name] [last name] order. Multiple surnames must be
entered in the last name field. For example, Hispanic names may be written in the order of given name,
father's last name, and mother's last name, e.g., “Juan Vega Santiago.” Thus the surname “VEGA SANTIAGO”
would be entered in the last name field with “JUAN” entered in the first name field. Some Hispanic surnames
consist of three names (e.g., father’s last name, mother’s last name, and husband’s father’s last name in the
case of a married woman). In that case all three would be entered in a last name field. Hispanic names do
not have middle names, so a multiple Hispanic given name such as “Rosa Maria” would be recorded in the
first name field. In some cultures names consist of multiple first names and a single family name, not
necessarily in (first name) (last name) order. For example, the Korean name “Kim, Chun Nam” consists of the
family name “Kim” and the first name “Chun Nam” separated by a comma and space. There is no middle
name. In this case “KIM” would be entered in the last name field and “CHUN NAM” would be entered in the
first name field. Nothing is entered in the middle name field. When an individual name is entered in a single
name field it should be entered in [first name] [middle name] [last name order regardless of any foreign
naming conventions. Thus, “Kim, Chun Nam” would be entered as “CHUN NAM KIM” in a single name field.
Punctuation and special characters should be used in names only when they are part of the name. For
example, the period in “Expedia.Com” should be included because it is part of the name. Entry of middle
initials is permitted when a middle name is unknown. Do not include a period after a middle initial when the
initial represents a name abbreviation. Abbreviations in names are prohibited unless an abbreviation is part
of a legal name or the name is unknown. A name suffix may be abbreviated, i.e. Junior can be JR, Senior can
be SR, the Third can be III, etc.
13. Reporting Cyber Events: Cyber events directly affecting the financial institution or the financial institution’s
customer are occurring on an ever-increasing basis. Since the implementation of the new FinCEN SAR in 2011,
a significant number of FinCEN SARs have been filed to record the events with the data being recorded in Part
V, the FinCEN SAR Narrative. The data collected and submitted has provided law enforcement with valuable
leads and insight into this emerging field. A review of the data reported indicates that prompt retrieval of
cyber event information is a critical step in combating malicious cyber activity. To facilitate and support
prompt identification and retrieval of malicious cyber event information, specific cyber fields (42, 43, and 44)
have been added to Part II, the Suspicious Activity Information section of the FinCEN SAR. These fields are not
meant to be exhaustive or to replace attachments. Use of these fields to highlight selected information (that
may also be in attachments) can assist law enforcement in identifying key indicators. Due to the growing
prevalence and technological sophistication of cyber-enabled financial crime, FinCEN encourages financial
institutions to develop a basic understanding of what comprises a cyber event. Being familiar with selected
key vocabulary is essential in describing these cyber events to law enforcement. Completion of cyber event
fields 42 to 44 is not mandatory, but is encouraged where financial institutions have sufficient capacity to do
so. While use of the fields may not be mandatory, filing on certain cyber events and cyber-enabled financial
crime may be mandatory under existing filing requirements—see FinCEN Advisory FIN-2016-A005 for more
information.
A principal source of cyber related information will be the financial institutions’ internal technology
department or external technology contractor. FinCEN recognizes that institutions have varying familiarity
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with and access to cyber-related information in their compliance departments and therefore encourages the
involvement of available IT resources on an ongoing basis. Financial institutions should review established
internal departmental protocols to ensure prompt review and reporting of cyber event information.
Reporting cyber event information is not a new requirement and financial institutions are expected to report
this information when available. To assist institutions in identifying when to use the new cyber fields, FinCEN
is providing the examples below. Please note that these examples highlight instances where an institution
may be limited in its ability to identify cyber-related information due to limits in cyber expertise or resource
availability. Each example is an acceptable and appropriate use of these fields.
Example 1.
Bank A is told by its customer, ABC Corp, that a recent wire payment issued from its account was fraudulent.
Bank A is told that fraudsters imitated the CEO of ABC Corp.’s e-mail to instruct ABC employees to wire
funds from ABC’s accounts at Bank A to an account at Bank B. ABC Corp tells Bank A that these fraudulent e-
mails were made to look like the CEO used the e-mail address [email protected] instead of the legitimate
[email protected]. These fraudulent e-mails appeared to be instructing employees to issue urgent
payments to one of ABC’s suppliers for $300,000. Bank A recognizes this as a Business E-mail Compromise
(BEC) scheme. In the FinCEN SAR narrative, Bank A describes the incident and mentions the term “BEC Fraud”
and FinCEN advisory FIN-2016-A003.
Bank A places the following information in the new fixed fields on the FinCEN SAR form:
Item 42: Cyber Event
Bank C files a FinCEN SAR with the following information in the new fixed fields:
Item 42: Cyber Event
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Example 4.
Bank D identifies an incident that targeted Bank D’s own systems, resulting in access to Bank D’s payment
systems and an attempted transfer of $50,000 through Bank D’s 123-wire system. Bank D’s compliance team
asks its IT department for additional technical information related to this incident, and whether there were
any key indicators associated with the event. Bank D’s IT department confirms that the incident was a cyber
event against Bank D, but is unable to spend resources locating additional information due to their
necessary focus on continuity of business operations. Bank D files a FinCEN SAR based on the available
information.
Bank D files a FinCEN SAR with the following information in the fixed fields:
Item 42: Cyber Event
Item 43:
a. IP address: 127.0.0.1
b. Date: 2017-01-30
c. UTC Time: 00:00:01
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Item *1 Type of filing: Check box 1a "Initial report" if this is the first report filed on the suspicious activity. Check box
1b "Correct/Amend prior report" if the report corrects or amends a previously-filed FinCEN SAR. See General
Instruction 3 for additional instructions on filing corrected or amended SARs. Check box 1c "Continuing activity
report" if the FinCEN SAR continues reporting on previously-reported suspicious activity. If the FinCEN SAR corrects a
previously-filed continuing activity report, both 1b and 1c must be checked. See General Instruction 4 for additional
instructions on filing continuing activity reports. Check box 1d “Joint report” if a FinCEN SAR of any filing type is filed
jointly by two or more financial institutions. See General Instruction 5 for additional instructions on filing joint reports.
If box 1b or 1c is checked, the prior report’s BSA Identifier (BSA ID) must be recorded in field 1e. Enter 14 zeros if the
prior report BSA ID is unknown.
3. Check:
a. If entity
b. If all critical* subject information is unavailable (does not include item *27)
Item 3a Check if entity: Check box 3a if the person described in Part I is an entity and not an individual. Item 3b Check
if all critical subject information is unavailable: Check box 3b if the information in Part I is unavailable for all critical
subject items except Item 27. These critical items (4, 5, 11, 12, 13, 14, 15, 16, 17, and 18) and their associated
“Unknown” fields must be left blank.
* 4. Individual’s last name or entity’s legal name
* 5. First name
a. (check if) unknown
Item *5 First name: Enter the individual's first name. If the first name is unknown leave item 5 blank and check box 5a
“Unknown.” Leave Item 5 and box 5a “Unknown” blank if box 3a or 3b is checked.
6. Middle name
Item 6 Middle name/initial: Enter the individual's middle name or initial. Leave this item blank if the middle name or
initial is unknown or box 3a is checked.
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7. Suffix
Item 7 Suffix name: Enter the individual’s suffix such as JR, SR, III, etc. Leave this item blank if the suffix is unknown or
the individual’s legal name does not include a suffix.
8. Gender
a. Male
b. Female
c. Unknown
Item 8 Gender: Select options 8a Male or 8b Female if individual’s gender is known. Select option 8c “Unknown” if the
individual’s gender is unknown. Leave Item 8 blank if the subject is an entity. Item 8 (Gender) does not create an
obligation for a financial institution to collect this data when such collection would be in conflict with the financial
institution’s obligations under any other federal law.
a. NAICS Code
Item 10 Occupation or type of business: Record the occupation, profession, or type of business of the individual or
entity recorded in Part I. Use specific descriptions such as doctor, carpenter, attorney, used car dealership, plumber,
truck driver, hardware store, etc. Do not use non- descriptive items such as businessman, merchant, retailer, retired,
or self-employed. If words like self-employed, unemployed, or retired are used, add the current or former profession
if known (e.g. self-employed building contractor, retired teacher, or unemployed carpenter). If the occupation or
business activity can be described in more detail, include the additional information in Part V.
Item 10a NAICS Code: select the North American Industry Classification System (NAICS) code for the occupation or
type of business entered in Item 10. Batch filers should only enter codes from the list of NAICS Codes authorized for
use in the FinCEN SAR and located on the BSA E- Filing Web Site (http://bsaefiling.fincen.treas.gov/main.html) or from
the U.S. Census Bureau NAICS list at https://www.census.gov/cgi-bin/sssd/naics/naicsrch?chart=2017. If the Census
Bureau list is used filers cannot substitute a sector code (such as 11 Agriculture, Forestry, Fishing and Hunting) for an
actual three to six number NAICS Code (such as 11114 Wheat Farming).
Items *11 - *14 Subject address items: Enter the subject's permanent street address, city, two or three letter
state/territory/province code (U.S./Canada/Mexico only), ZIP Code or foreign postal code, and two letter country or
U.S. Territory code. Complete any address item that is known, even if the complete address is unknown. If an address
item is unknown, leave that item blank and check box 11a "Unknown." If box 3b is checked all address items and
check boxes must be blank. See General Instruction 7 for additional information on entering addresses. Multiple sets
of address fields may be completed if multiple present and past subject addresses are known.
*11. Address
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*16. TIN (enter number in space provided and check appropriate type below)
b. (check if) unknown
Item *16 TIN: Enter the subject's U.S. taxpayer identification number (TIN) or foreign equivalent without formatting or
punctuation. If the number is unknown, check box 16a "Unknown" and leave Item 16 blank. Leave item 16 and box
16a “Unknown” blank if box 3b is checked. See General Instruction 9 for information on entering identifying numbers.
17. TIN type
a. EIN
b. SSN-ITIN
c. Foreign
Item 17 TIN type: Identify the type of TIN recorded in Item 16. Select option 17a “EIN” if the subject has a U.S.
Employer Identification Number (EIN). Box 3a “If entity” must be checked because an EIN is assigned only to an entity.
Select option 17b “SSN-ITIN” if the subject has a U.S. Social Security Number (SSN) or Individual Taxpayer
Identification Number (ITIN). Select option 17c “Foreign” if the subject has a foreign TIN of any type. Box 3a must be
checked if the foreign subject is an entity. If 17c is checked, record in Part V the name of the country that issued the
foreign TIN. Enter the subject’s TIN type if known even if the actual TIN is unknown and Item 16a “Unknown” is
checked. If a 9-digit TIN is entered in Item 17 but the TIN type is unknown, select option 17a “EIN” if the subject is an
entity and option 17b “SSN-ITIN” if the subject is an individual. TINs that are not 9 digits are presumed to be foreign,
so option 17c “Foreign” would be selected.
Item *18 Form of identification: Enter in Item 18 the information used to identify the individual or entity. Select
option 18b if the identification was a driver's license or state ID, 18c if the identification was a passport or 18d if the
identification was an alien registration. Select option 18z if a different identification was provided and describe that
identification in the "Other" text field. “Other” identification could include such things as an entity’s business license
or incorporation documents, corporate ID cards, local government ID cards, etc. Enter the identification number in
field 18e "Number." Do not include formatting such as hyphens or periods. Select the appropriate state option in
field 18f "Issuing state" if the identification issuer was a U.S., Canadian, or Mexican state, territory, or province. Select
the appropriate country option in field 18f "Country" if the issuer was a country. If field 18f “Issuing state” contains an
entry, then 18g “Country” must contain “US,” “CA,” or “MX” as appropriate. Enter the data on the country that issued
the ID or where the ID was issued. See General Instruction 7 for information about the codes to enter in state and
country items. If the identification issuer does not have a code, select the option for the issuer's country in field 18g.
For example, if the issuer was the London Police Department United Kingdom would be selected in 18g. Record the
name and nature of the issuer in Part V. Enter all identification data that is available. Check box 18a “Unknown” only if
all identification information is unknown but the subject is known. Leave all fields in Item 18 blank if box 3b has been
checked. Multiple sets of Item 18 fields may be completed if multiple types of identification for a subject are known.
See General Instruction 9 for information on entering identifying numbers.
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Item *19 Date of birth: If the subject is an individual enter the subject's data of birth in Item 19. Filers of FinCEN’s
discrete FinCEN SAR must use the format MM/DD/MMYY where MM = month, DD = day, and YYYY = year. Batch
filers must use the format YYYYMMDD. If the birth day and or month is unknown, enter “00” for the unknown day
or month. For example, a date of birth with an unknown day in February 1978 would be entered as 02/00/1978 in a
discrete FinCEN SAR and 19780200 in a batch filed FinCEN SAR. Do not enter zeros for the year if the year is
unknown. If the year of birth or the complete date of birth is unknown, check box 19a "Unknown" and leave Item
19 blank. If box 3a or b is checked, Item 19 and box 19a “Unknown” must be blank.
Item 21a Ext. (if any): Enter the telephone extension associated with the subject's telephone number. Leave Item
21a blank if there is no extension or the extension is unknown.
Item 23 Corroborative statement: Select "Yes" if the subject individual has made a statement to the filer admitting to
involvement in or otherwise substantiating the suspicious activity. Record in Part V the nature of the corroborative
statement and how it was recorded, i.e. written confession, verbal statement, etc. Select "No" if no corroborative
statement was made to the filer. Leave Item 23 blank of the subject is an entity
24. Relationship of the subject to an institution listed in Part III or IV (check all that apply)
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a. Institution TIN
b. Accountant
c. Agent
d. Appraiser
e. Attorney
f. Borrower
g. Customer
h. Director
i. Employee
j. No relationship to institution
k. Officer
l. Owner or Controlling Shareholder
z. Other (and specify type in space provided)
Item 24 Relationship of the subject to an institution: If the subject has a relationship with a financial institution or
individual listed in Part III or Part IV, enter the financial institution's TIN from Items 55 or 81 in field 24a "Institution
EIN." Select all options 24b through 24l (but not 24j no relationship) that describe the relationship. If the relationship
is not covered by any of options 24b through 24l, select option 24z "Other" and enter a brief description of the
relationship in the "Other" text field. Avoid descriptions that are too general. For example, the entry "broker" should
be made more specific by indicating the relationship was "real estate broker," "securities broker," or "mortgage
broker." If necessary, describe the relationship more fully in Part V. If the subject has no relationship with any of the
financial institutions in Part III or Part IV, record box 24j "No relationship to institution” once for all institutions and
enter the Part IV filing institution’s EIN in the Item 24 “Institution TIN” field. Do not record box 24j for the subject if a
relationship exists with any institution, even when there is no relationship with other institutions." The FinCEN SAR
cannot be a joint FinCEN SAR if any of the options 24h “Director,” 24i “Employee,” 24k “Officer,” or 24l “Owner or
Controlling Shareholder” have been selected. If the subject had a relationship with a financial institution recorded in
Part III but the financial institution’s TIN was unknown, record the relationship but leave field 24a blank. If the subject
has relationships with multiple Part III and Part IV financial institutions, complete a separate set of Item 24 fields for
each financial institution. If more than one of 24h “Director,” 24i “Employee,” 24k “Officer,” or 24l “Owner or
Controlling Shareholder” is selected and/or the status or action date is different for each, an Item 24 for each must be
completed.
Item 25. If item 24h, i, k, or l is selected: If any of boxes 24h, 24i, 24k, or 24l are selected, select the appropriate Item
25 option to indicate the status of the relationship. Select option 25a if the relationship continues. Select option 25b
if the subject was terminated, 25c if the subject was suspended or barred, or 25d if the subject resigned. If multiple
sets of Item 24 fields are completed on a subject, complete an Item 25 field for each set.
* 27. Financial Institution TIN and account number(s) affected that are related to subject, if any.
a. (check if) No known accounts involved
b. (check if) Non-U.S. financial institution
c. TIN
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d. account number
e. (check if) closed
Item 27 Financial institution TIN and account number(s) affected that are related to the subject, if any: Enter in Item
27 information about any accounts involved in the suspicious activity that are related to the subject recorded in Part
I. Enter account numbers without formatting or special characters such as spaces, hyphens, or periods. See General
Instruction 9 for information about entering account numbers in fields. An account is related to a subject if the
subject owns the account, has control over the account, or conducted activity in or through an account the subject
does not own or control. Check box 27a "No known acct. involved" if no account related to the subject is involved in
the suspicious activity. If box 27a is checked, then all other options in Item 27 will be blank. Check box 27b "Non-US
Financial Institution" if the account is located at a foreign financial institution. Enter in field 27c the TIN, if known, of
the financial institution where the account is held. If the TIN is unknown leave the TIN field blank. Enter the account
number involved in field 27d. If the account is closed, check the "Yes" box. If multiple account numbers are involved
in the suspicious activity, complete an additional set of account number fields for each account number. Record
account numbers involved in the suspicious activity that are related to the subject even if the TIN or name of the
financial institution is unknown. If the TIN of a financial institution associated with an account number entered in
27d is unknown, record the institution name and associated account number in Part V (example: “The account
number 123654987 is held at First Federal Bank.”). If the filer is aware that the subject has an account involved in the
suspicious activity with a financial institution listed in Part III but the account number is unknown, record the
financial institution TIN in Item 27a but leave the associated account number field blank. Explain the missing
account number in Part V. The subject’s relationship to any account recorded in Item 27 must be clearly defined in
Part V unless the subject is the owner of the account (example: “The subject made unauthorized purchases using a
stolen debit card for account 3456789 owned by his aunt.”).
Item 28 Subject's role: Record the subject's role in the suspicious activity by selecting the appropriate option. Select
option 28a "Purchaser/Sender" if the subject purchased or sent the financial instrument(s) or product(s) involved in
the suspicious activity. Select option 28b "Payee/Receiver" if the subject was the payee or receiver of the
instrument(s) or product(s). Select option 28c "Both a & b" if the subject was both a purchaser/sender and
payee/receiver. Instruments and products are not limited to the instruments and products listed in Items 45 and
46.
Note: Item 28 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial instruments
Item *29 Amount involved in this report: Enter the total amount involved in the suspicious activity for the time period
of this report. Multiple amounts will be aggregated and the total recorded in Item 29. This requirement applies even
when the amounts involve different transaction types, such as when some are deposits and some are withdrawals. All
amounts are aggregated and recorded as the total amount. If some amounts are known and some are unknown, the
known amounts are aggregated and the total is recorded in Item 29. Unknown amounts are explained in Part V. If the
amount or all amounts involved in the suspicious activity are unknown, box 29a “Amount unknown” is checked and the
Item 29 amount field will be blank. Explain in Part V why the amount or amounts are unknown. Check box 29b “No
amount involved” and leave the amount field blank if the suspicious activity did not involve any monetary amounts.
Never enter “0” in the Item 29 amount field under any circumstance. Never enter a small amount such as $1 or $5 to
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complete the amount field when that entry is not the actual amount involved. If the FinCEN SAR is a continuing report
with box 1c “Continuing activity report” checked, enter only the total of amounts that are involved for the time period
covered by this FinCEN SAR. Do not include amounts from prior FinCEN SARs in Item 29. Prior FinCEN SAR amounts
and the current FinCEN SAR total amount are aggregated in Item 31 “Cumulative amount only if box 1c (continuing
activity report) is checked.” See General Instruction 9 for information on entering amounts.
Item *30 Date or date range of suspicious activity for this report: Enter the suspicious activity date or date range for
this report. If the suspicious activity occurred on a single day, enter that date in field 30a "From" and leave field 30b
"To" blank. If the suspicious activity occurred on multiple days, enter the earliest date of suspicious activity in field
30a and the most-recent date of suspicious activity in field 30b. If the exact date(s) of the suspicious activity is (are)
unknown, enter a date range that the filer believes will encompass the date(s) of the suspicious activity. Explain the
nature of this date range in Part V. If the FinCEN SAR involves continuing activity with box 1c "Continuing activity
report" checked, enter only the date range covered by this FinCEN SAR. Record in Part V the aggregated date range
of all FinCEN SARs filed on the continuing suspicious activity. Use the format MM/DD/YYYY for dates in a discrete
FinCEN SAR and the format YYYYMMDD for dates in a batch-filed FinCEN SAR.
31. Cumulative amount (only applicable when”Continuing activity report” is checked in Item 1)
Item 31 Cumulative amount: Enter the cumulative amount involved in the suspicious activity in Item 31 if box 1c
"Continuing activity report" is checked. The cumulative amount represents the total amount involved in all FinCEN
SARs filed on the suspicious activity, including the current FinCEN SAR. If box 1c is checked and the cumulative dollar
amount is unknown because all dollar amounts are unknown or no dollar amount is involved, enter zero (0) and
explain the entry in Part V. If some dollar amounts are known while others are unknown, enter the total of all known
amounts in Item 31 and explain the nature of the unknown amounts in Part V. See General Instruction 10 for
information on entering amounts. Leave Item 31 blank if box 1c is not checked.
Items 32 - 41 Types of suspicious activity: Use the suspicious activity category Items 32 through 41 to record the
type(s) of suspicious activity being reported. Check all boxes that apply to the suspicious activity. If a category applies
but none of the options apply, check the category’s box “z Other” and briefly describe the type of suspicious activity in
the associated text field. If necessary, explain the type of suspicious activity in more detail in Part V.
Note: Items 32-41 are considered critical. At least one item in 32 to 41 must be checked.
32. Structuring
a. Alters or cancels transaction to avoid BSA recordkeeping requirement
b. Alters or cancels transaction to avoid CTR requirement
c. Suspicious inquiry by customer regarding BSA reporting or recordkeeping requirements
d. Transaction(s) below BSA recordkeeping threshold
e. Transaction(s) below CTR threshold
z. Other (specify type of suspicious activity in space provided)
34. Fraud
a. ACH
b. Advance fee
c. Business loan
d. Check
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e. Consumer loan
f. Credit/Debit card
g. Healthcare/Public or private health insurance
h. Mail
i. Mass-marketing
j. Ponzi scheme
k. Pyramid scheme
l. Securities fraud
m. Wire
z. Other (specify type of suspicious activity in space provided)
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e. Embezzlement/theft/disappearance of funds
f. Forgeries
g. Human smuggling
h. Human trafficking
i. Identity theft
j. Little or no concern for product performance penalties, fees, or tax consequences
k. Misuse of position or self-dealing
l. Suspected public/private corruption (domestic)
m. Suspected public/private corruption (foreign)
n. Suspicious use of informal value transfer system
o. Suspicious use of multiple transaction locations
p. Transaction with no apparent economic, business, or lawful purpose
q. Transaction(s) involving foreign high risk jurisdiction
r. Two or more individuals working together
s. Unlicensed or unregistered MSB
z. Other (specify type of suspicious activity in space provided)
39. Insurance
a. Excessive insurance
b. Excessive or unusual cash borrowing against policy/annuity
c. Proceeds sent to or received from unrelated third party
d. Suspicious life settlement sales insurance (e.g. STOLIs, Viaticals)
e. Suspicious termination of policy or contract
f. Unclear or no insurable interest
z. Other (specify type of suspicious activity in space provided
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Item 42, Cyber event: Complete item 42 to indicate if the cyber event was directed against the financial institution or
its customer/account holder. Events against the institution may include, but not limited to, a digital denial of service
(DDoS), an attempt to break (hack) into the financial institutions computer system or an attempt to take over the
financial institutions “wire transfer system,” the financial institutions website, a Business E-Mail Attack (BEA), etc.
Examples of cyber events against the financial institutions customer may include the takeover (or attempted takeover)
of the customer’s account, the sending of bogus e-mails that appear to come from the customer directing various
financial transactions that do not follow the customers normal account activity, etc.
text field).
44a2 Event value text field (Date associated with the value in 44a1).
44a3 Event value text field (Timestamp associated with the value in 44a1).
44b. Command & Control URL/Domain
44b1 Event value text field. (each entry of 44b must have a corresponding event value
text field)
text field)
44d. Media Access Control (MAC) Address
44d1 Event value text field (each entry of 44d must have a corresponding event value
text field).
44e. Port
44e1 Event value text field. (each entry of 44e must have a corresponding event value
text field)
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44f1 Event value text field. (each entry of 44f must have a corresponding event value
text field)
text field)
44h. Suspicious IP Address
44h1 Event value text field. (each entry of 44h must have a corresponding event value
text field)
44h2 Event value Date associated with the value in 44h1 (discrete format MM/DD/YYYY
and batch format YYYYMMDD).
44i1 Event value text field. (each entry of 44i must have a corresponding event value
text field)
text field)
44z. Other
45. Were any of the following product type(s) involved in the suspicious activity? Check all that apply:
a. Bonds/Notes
b. Commercial mortgage
c. Commercial paper
d. Credit card
e. Debit card
f. Deposit account
g. Forex transactions
h. Futures/Options on futures
i. Hedge fund
j. Home equity line of credit
k. Home equity loan
l. Insurance/Annuity products
m. Microcap securities
n. Mutual fund
o. Options on securities
p. Prepaid access
q. Residential mortgage
r. Security futures products
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s. Stocks
t. Swap, hybrid or other derivative
z. Other (specify type in space provided)
Item 45 Product types involved in suspicious activity: Check all Item 45 boxes that apply to record the product
type(s) involved in the suspicious activity. Option 45f ‘Forex transactions” includes all foreign exchange transactions
both on and off-exchange, including futures and options on foreign exchange. Option 45g “Futures/Options on
futures” includes futures and options on any "commodity," as that term is defined in Section 1a(4) of the
Commodity Exchange Act, including broad-based security indexes. Option 45s “Swap, hybrid or other derivative”
includes all derivatives not included above including those traded over-the-counter and off-exchange. If the
product type is not covered by options 45a through 45s, check box 45z "Other (list below)" and enter a brief
description in the associated text field. If necessary provide a more detailed product type (such as commodity
futures contracts, options on commodity futures contracts, commodity options, and OTC agricultural trade options)
in Item 48 “Product/instrument description” or in Part V. If there are multiple product types not covered by Item 45,
record one in Item 45z "Other (List below)” and all others in Part V.
46. Were any of the following instrument type(s)/payment mechanism(s) involved in the suspicious activity? Check all
that apply:
a. Bank/cashier’s check
b. Foreign currency
c. Funds transfer
d. Gaming instruments
e. Government payment
f. Money orders
g. Personal/Business check
h. Travelers checks
i. U.S. Currency
z. Other (specify type in space provided)
Item 46 Instrument types involved in suspicious activity: Check all Item 46 boxes that apply to record the instrument
type(s) involved in the suspicious activity. If the instrument type is not covered by options 46a through 46i, check
box 46z "Other (List below)" and enter a brief description in the associated text field. If necessary provide a more-
detailed description of the instrument type in Part V. If there are multiple instrument types not covered by Item 46,
record one in Item 46 "Other (List below)” and all others in Part V.
47. Commodity type (if applicable)
Item 47 Commodity type: If a commodity is involved in the suspicious activity, record the commodity type in Item
47. Multiple Item 47 fields should be completed if multiple commodity types are involved in the suspicious activity.
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Item 50 CUSIP® number: Enter in Item 50 the CUSIP® (Committee on Uniform Securities Identification Procedures)
number of any securities products such as stocks and bonds involved in the suspicious activity. Multiple Item 50
fields should be completed if there are multiple CUSIP numbers for multiple securities products involved in the
suspicious activity.
---------------- Part III Information about Financial Institution Where Activity Occurred ------------
Part III records information about the financial institution(s) where the suspicious activity occurred. Complete a
separate Part III record on each financial institution involved in the suspicious activity. If box 1d “Joint report” is
checked there must be two or more Part III records in the FinCEN SAR, one for the Part IV filing institution or filer
subsidiary and one for each joint filer. If a financial institution recorded in Part III has branches involved in the
suspicious activity, record the branch information in Items 68 through 74. Information for up to 99 branches can be
recorded in a single FinCEN SAR. A branch is a location (such as an office or ATM) owned by the financial institution
but located separately from the financial institution’s headquarters. If a reporting financial institution has agents
where the suspicious activity occurred, a separate Part III must be prepared on each agent. An agent is an
independent financial institution (such as a supermarket that sells money orders or an independent insurance
agent) that has a contractual relationship with the reporting financial institution to conduct financial transactions.
Do not place agent information in branch fields. Generally, a branch operates under the same TIN as the financial
institution. An agent has a TIN different from the financial institution. Financial institution as used in Part III includes
individuals acting as sole proprietorship financial institutions using their personal Social Security Number (SSN) or
Individual Taxpayer Identification Number (ITIN).
Item *51 - Type of financial institution: Select the appropriate type of financial institution that best describes the
financial institution recorded in Item 51. If none of those options apply, select “Other” and enter a brief description
in the associated text field. If necessary, include a more- detailed description in Part V.
NOTE: If the financial institution is a dealer in precious metals, stones, or jewels, select option “Other” and enter
“DEALER IN PRECIOUS METALS STONES JEWELS” in the associated text field.
Item *52 Primary federal regulator: Select the appropriate option to identify the primary federal regulator or BSA
examiner of the financial institution recorded in Part III. If more than one regulator option could apply, enter the
code for the regulator that has primary responsibility for enforcing compliance with the BSA. If Item 51 option
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“Casino/Card Club,” “Insurance Company,” or “MSB” was selected, the Item 52 entry must be “Internal Revenue
Service (IRS).” If the institution recorded in Part III is subject to U.S. law and none of the other codes apply, select
option “Internal Revenue Service (IRS).” If the institution recorded in Part III is not subject to U.S. law, then select
option “Not Applicable.”
53. If item 51a is checked, indicate type of gaming institution (check only one)
a. State licensed casino
b. Tribal authorized casino
c. Card club
z. Other (specify type of gaming institution in space provided)
Item 53 Gaming institution type: If option 51a was selected indicating the financial institution is a gaming
institution such as a casino or card club, record the type of gaming institution by checking the appropriate box. If
none of the options 53a through 53c are appropriate, check box 53z "Other" and provide a brief description in the
associated text field. If necessary, include a more detailed description in Part V.
54. If item 51e is checked, indicate type of Securities and Futures institution or individual where activity occurred -
check the boxes of all types that apply to this report.
a. Clearing broker – securities
b. Execution-only broker securities
c. Futures commission merchant
d. Holding company
e. Introducing broker - commodities
f. Introducing broker - securities
g. Investment adviser
h. Investment company
i. Retail foreign exchange dealer
j. Self-clearing broker-securities
k. Subsidiary of financial/bank holding company
z. Other (specify type of institution or individual in space provided)
Item 54 Securities and futures type: If option 51e was checked indicating the financial institution is part of the
securities and futures industries, check all boxes that apply to the reported suspicious activity. If none of options
54a through 54k apply, check box 54z "Other" and record a brief description of the type in the associated text field.
Examples of this are commodity pool operator or commodity trading adviser. If necessary, include a more-detailed
description in Part V.
z. Identification number
Item 55 Financial institution identification number: Select the appropriate option if the financial institution recorded in
Part III has a Central Registration Depository (CRD) number, an Investment Adviser Registration Depository (IARD)
number, a National Futures Association (NFA) number, a Research Statistics Supervision Discount (RSSD) number,
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National Association of Insurance Commissioners (NAIC Code), Mortgage (NMLS ID) or a Securities and Exchange
Commission (SEC) Reporting File Number (RFN). Do not enter an SEC Central Index Key (CIK) number in place of the
RFN. Record the number in field 55h. See General Instruction 8 for information on entering identifying numbers.
Item 56 Financial institution role in transaction: Check the box “Selling location” if the customer purchased at the
Part III financial institution the products or instruments recorded in Items 45 or 46. Check the box “Paying location”
if the customer received payment from the Part III financial institution for the products or instruments recorded in
Items 45 or 46. Check the box “Both” if the Part III financial institution was both a paying and selling location for the
products or instruments recorded in Items 45 or 46.
Note: Item 56 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial
instruments.”
Item 57 Legal name of financial institution: Enter the legal name of the financial institution as recorded on articles
of incorporation or other documents establishing the institution. Record as the legal name the full name of an
individual, such as a sole proprietorship, acting as a financial institution. Enter the individual’s name in (first name)
(middle name) (last name) or equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc. Check box 57a
“Unknown” if the legal name is unknown and leave Item 57 blank.
Item 58 Alternate name: If the financial institution recorded in Item 58 has a separate doing business as (DBA)
name, enter that name here. If an individual recorded in Item 58 has a separate also known as (AKA) name, enter
that name here also. Do not include the acronyms DBA or AKA with the alternate name.
* 59. TIN
a. (check if) unknown
Item 59 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the financial institution or
individual recorded in Item 57. See General Instruction 8 for information on entering identifying numbers. Check
box 59a “Unknown” if the TIN is unknown and leave Item 59 blank.
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Item 60 TIN type: Select the option for the type of TIN entered in Item 59. If the TIN in Item 59 is unknown and the
Item 57 financial institution has a U.S. address, select TIN Type option “EIN” if the financial institution is an entity and
“SSN-ITIN” if the financial institution is an individual. If the financial institution has a foreign address and the TIN is
unknown, select “Foreign.”
Items *61 - *65 Financial institution address items: Enter the financial institution's permanent street address, city,
two or three letter state/territory/province code (U.S./Canada/Mexico only), ZIP Code or foreign postal code, and
two letter country code. If an address item is unknown, leave that item blank and check the item’s "Unknown" box.
Leave Item 63 State blank if the state is unknown or the country is not the U.S. or a U.S. Territory, Canada, or
Mexico. See General Instruction 6 and the Part III introductory instructions for additional information on entering
address data.
*61. Address
a. (check if) unknown
*62. City
63. State
*65. Country
Item 66 Internal control/file number: Enter the internal control number or file number, if applicable, assigned to the
FinCEN SAR by the financial institution. This number should be unique to the FinCEN SAR if possible, allowing
interested parties such as law enforcement or the financial institution to reference the FinCEN SAR without
committing a potentially illegal disclosure of FinCEN SAR data.
Item 67 Loss to financial institution: If the financial institution has suffered a loss because of the suspicious activity,
record the amount of loss in Item 67. If some losses are known and other losses unknown, enter the total of known
losses as of the date of filing. If the FinCEN SAR is a continuing FinCEN SAR because box 1c was checked, enter the
loss amount for the current FinCEN SAR in Item 67 and record in Part V the total aggregated losses for all FinCEN
SARs filed on the suspicious activity. The amount entered in this field cannot be zero and cannot be greater than
the amount in Item 29 “Amount involved in this report.” See General Instruction 10 for information on entering
amounts.
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Item 68 Branch’s role: Check the box “Selling location” if the branch sold the products or instruments recorded in
Items 45 or 46 to a customer. Check the box “Paying location” if a customer received payment from the branch for
the products or instruments recorded in Items 45 or 46. Check the box “Both” if the Part III financial institution branch
was both a paying and selling location for the products or instruments recorded in Items 45 or 46. This item must be
blank if no branch is involved in the suspicious activity. If multiple branches are involved in the suspicious activity, a
separate Item 68 must be prepared for each branch.
Note: Item 68 generally applies to institutions such as MSB’s or depository institutions through which the subject
conducted transactions involving wire transfers, traveler’s checks, money orders, or like products/financial
instruments.
Items *69 and 71-74 Branch address items: See the instructions for Items *61 - *65, the Part III introductory
instructions, and General Instruction 6 for information on entering branch address data. If a branch address item is
unknown, leave that item blank. Item 74 “Country” cannot be blank if any other branch address information is
recorded. If no branch was involved in the suspicious activity or the branch country is unknown, check box 69a and
leave the branch address items blank. If multiple branches are involved in the suspicious activity, complete a set of
branch address items for each branch.
71. City
72. State
*74. Country
------------------------------- Part IV Filing Institution Contact Information -----------------------------
Part IV records information about the lead financial institution, holding company, agency, or other entity that is
filing the FinCEN SAR. There must be only one Part IV record in a FinCEN SAR. Do not include information about
joint filers in a Part IV record. Joint filer information must be reported in a Part III record. Financial institution as
used in Part IV includes individuals acting as sole proprietorship financial institutions using their personal Social
Security Number (SSN) or Individual Taxpayer Identification Number (ITIN).
*75. Primary Federal Regulator (instructions specify banking agencies, SEC, CFTC, IRS)
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Item *75 Primary federal regulator: Select the appropriate option from the drop-down list to identify the Primary
Federal Regulator or BSA Examiner of the filing institution. If more than one regulator option could apply, select the
regulator that has primary responsibility for enforcing compliance with the BSA. If Item 79 option “Casino/Card
Club,” “Insurance Company,” or “MSB” is selected, the Item 75 entry must be “Internal Revenue Service (IRS).” If the
financial institution filing the FinCEN SAR is subject to U.S. law and none of the other codes apply, the entry must
be “Internal Revenue Service (IRS).” If the FinCEN SAR is being filed by a government agency or if the financial
institution filing the FinCEN SAR is not subject to U.S. law, the entry must be "Not Applicable.”
*76. Filer name (Holding company, lead financial institution, or agency, if applicable).
Item *76 Filer name: Enter the legal name of the filing institution as recorded on articles of incorporation or other
documents establishing the institution. Enter the full name of the filer if the filer is an individual, such as a sole
proprietorship, acting as a financial institution. If an individual’s name is recorded, enter the name in (first name)
(middle name) (last name) or equivalent format, e.g. John Jacob Doe or Richard R. Roe II, etc.
*77. TIN
Item *77 - TIN: Enter the Taxpayer Identification Number (TIN), either U.S. or foreign, of the financial institution or
individual recorded in Item 76. See General Instruction 8 for information on entering identifying numbers.
Item *78 - TIN type: Record the type of TIN entered in Item 77 by selecting the appropriate option.
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Item *79 - Type of financial institution: Select the appropriate type of financial institution that best describes the
filing institution recorded in Item 76. If none of those options apply, select “Other” and enter a brief description in
the associated text field. If necessary, include a more- detailed description in Part V.
NOTE: If the financial institution is a dealer in precious metals, stones, or jewels, select option “Other” and enter
“DEALER IN PRECIOUS METALS STONES JEWELS” in the associated text field.
80. Type of Securities and Futures institution or individual filing this report - check the boxes of all types that apply to
this report.
a. Clearing broker - securities
b. CPO/CTA
c. Execution-only broker securities
d. Futures commission merchant
e. Holding company
f. Introducing broker - commodities
g. Introducing broker - securities
h. Investment adviser
i. Investment company
j. Retail foreign exchange dealer
k. Self-clearing broker-securities
l. SRO Futures
m. SRO Securities
n. Subsidiary of financial/bank holding company
z. Other (specify type of institution or individual in space provided)
Item 80 - Securities and futures type: If option 80e “Securities/Futures” was selected, check all boxes that apply to
indicate the type of securities and futures institution that is filing the FinCEN SAR. If none of options 80a through
80nl apply, check box 80z "Other" and record a brief description of the type in the associated text field. If necessary,
include a more-detailed description in Part V.
z. Identification number
Item 81 - Filing institution identification number: See instructions for Item 55.
*82. Address
* 83. City
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*84. State
* 86. Country
87. Alternate name, e.g., AKA if individual; DBA/ trade name if entity. See instructions
for Item 58.
Item 89 - LE contact agency: Enter the name of the law enforcement agency, if any, which has been informed of the
suspicious activity.
NOTE: If more than one LE agency has been contacted about the suspicious activity, record the information on one
agency in Items 89-92 and the information on additional agencies in Part V.
Item 90 - LE contact name: Enter the name of the person contacted at the law enforcement agency.
Item 91 - LE contact phone number: Enter the law enforcement contact telephone number. See General Instruction 7
for information on entering telephone numbers.
Item 91a - Extension: Enter the extension, if any, of the law enforcement contact telephone number
Item 92 – LE contact date: Enter the most-recent date the law enforcement agency was contacted about the
suspicious activity. If the agency was contacted on multiple dates, record the earlier contact dates in Part V.
Discrete filers will use the format MM/DD/YYYY while batch filers will use the format YYYYMMDD.
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Item 93 - Filing institution contact office: Enter the name of the filing institution contact office where additional
information about the FinCEN SAR or supporting documentation can be requested. If the FinCEN SAR is jointly
filed, enter in Part V the contact office and telephone number information for all Part III joint filers.
*94. Filing institution contact office phone number including area code
a. Extension, if any
Item 94 - Filing institution contact office phone number: Enter the contact office telephone number. See General
Instruction 7 for additional instructions on entering telephone numbers.
Item 94a - Extension: Enter the extension, if any, of the contact office telephone number.
Item 95 - Date filed: Enter the date the FinCEN SAR is filed. This date will be entered automatically when a discrete
FinCEN SAR is electronically filed. Batch filers will report this date in YYYYMMDD format.
The narrative section of the report is critical to understanding the nature and circumstances of the suspicious
activity. The care with which the narrative is completed may determine whether the described activity and its
possible criminal nature are clearly understood by investigators. Filers must provide a clear, complete, and concise
description of the activity, including what was unusual or irregular that caused suspicion. This description should
encompass the data provided in Parts I through III, but should include any other information necessary to explain
the nature and circumstances of the suspicious activity. Filers should provide any information the filers believe
necessary to better enable investigators to understand the reported suspicious activity. Narratives must be
completed in English. Filers should use the following checklist as a guide for preparing the narrative:
If filers have additional information pertaining to items in Parts I through IV this information should
be recorded in the narrative and referenced to the item number.
If this report is a corrected or amended report, complete the report in its entirety with whatever
corrections or amendments were required. Describe the corrections or amendments at the beginning
of the narrative.
If this report is a continuing report, describe the circumstances surrounding the suspicious activity for the
90-day period encompassing the report. Include information from prior FinCEN SAR narratives only when it
is necessary for an understanding of the nature and circumstances of the suspicious activity. Never include
the entire narratives of the prior FinCEN SARs.
If any item in the report was insufficient for recording all item data held by the filer, or if an item’s
instructions require entry of additional data or explanation in the narrative, record the additional data
referenced by item number in the narrative.
Information provided in other sections of the FinCEN SAR need not be repeated in the narrative unless
necessary to provide a clear and complete description of the suspicious activity.
Describe the conduct or transaction(s) that caused suspicion. If appropriate, this description should
be chronological when the activity involves multiple instances or encompasses more than one day.
Explain whether any transaction(s) involved were completed or only attempted.
Explain who benefited and how they benefited, financially or otherwise, from the activity.
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Describe all supporting documentation and retain the documentation for five years.
DO NOT include supporting documentation with the FinCEN SAR. (See General Instruction 6.)
If the FinCEN SAR is jointly-filed, name all joint filers and describe the nature of supporting document held
by the joint filers. Provide the contact office name and telephone number for each joint filer.
Describe and retain any evidence of cover-up or evidence of an attempt to deceive federal or state
examiners or others
Describe and retain any admission or explanation of the activity or transaction(s) provided by the
subject(s), witness(s), or other person(s), including to whom and when it was given.
Indicate where the suspicious activity took place, e.g. branch, cage, gaming pit, agent location, etc.
Indicate whether the suspicious activity is an isolated incident or related to other activity.
Indicate whether any U.S. or foreign currency or other negotiable instruments were involved. If
foreign currency or other foreign instruments, provide the foreign amount, currency name, and
country of origin.
Indicate if there is any litigation related to the activity by specifying the name of the litigation and
court where the action is pending.
Describe the nature of losses and recoveries related to the suspicious activity, including
aggregated losses and recoveries in continuing activity.
Identify the names of financial institutions associated with account numbers when the financial
institution TINs were unknown.
If the subject is a foreign national provide all available information on the subject’s passport(s),
visa(s), and other identification. Include identifying data such as issuing date, country, document
numbers, issuing authority, and nationality.
If the suspicious activity involves transfers of funds to or from a foreign country or currency
exchanges involving foreign currencies, identify the foreign currency, country of issue, and the
source or destination of the funds.
If a subject involved in the suspicious activity has an insider relationship with a financial institution,
describe the subject’s position with the financial institution and how that position related to the
suspicious activity.
Provide information on the victims of the suspicious activity only when it is necessary for a
complete understanding of the activity. DO NOT record victim information in a Part I Subject
Information record.
Provide information about the financial institution’s business policies and practices only if it is
necessary for a complete understanding of the suspicious activity. DO NOT include legal
disclaimers in the narrative.
Do not include tabular data in a FinCEN SAR narrative. Such data should be reported in an
appropriate comma separated values attachment.
If this SAR contains information provided by another financial institution under the 314(b) Voluntary
Information Sharing Program, include in the narrative the statement “This SAR contains 314(b) data.
Filers can include with a FinCEN SAR an attachment containing tabular data (such as transaction data) that
provides additional suspicious activity information not suitable for inclusion in the narrative. This file must
be an MS Excel-compatible comma separated value (CSV) file with a maximum size of 1 megabyte. Discrete
FinCEN SAR filers can attach this file by clicking the “Add Attachment” button on the discrete FinCEN SAR
header page and following the instructions provided. Batch filers must follow the instructions in Attachment
D – Batch Attachments to add CSV files to a batch file.
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EXAMPLE: SARXST.20170609153015.ABCPreparingFirm.xml
For more information on how to setup an SDTM connection, please direct them to the BSA E-Filing Help via the
Support Request Form. The Help Desk hours of operation are M-F 8:00 AM to 6:00 PM, Eastern Time (closed on
federal holidays).
*Please be advised that IBM’s Connect:Direct software is scheduled to be replaced with IBM’s Sterling File Gateway software in 2020.
**You can verify your filing organization’s SDTM_UID by having a Supervisory User for your organization login to the BSA E-Filing
System and select “Manage Users.”
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NOTE: Please be advised that when entering data into an Excel spreadsheet prior to saving it as a comma
separated (.CSV) file, the default behavior for numeric data entered into cells is to convert numeric values over 11
characters into scientific notation. For example, the value of 123456789123 is converted to 1.23457E+11 after
entry. When the Excel spreadsheet is saved to a comma separated (.CSV) fill, this visible format is retained and
when opened the entire original number is not displayed, 123456789123, but rather 1.23457E+11. To avoid this
behavior, please ensure that your workbook cells are formatted as text prior to entering data in the cell. This can
be accomplished by selecting the column, right clicking the mouse and selecting Format Cells, and then selecting
Text under Category, and then OK. This must be done before entering the data, not after.
While the BSA E-Filing System limits the number of attachments for a single FinCEN SAR to one (1) CSV file, batch
filers must abide by the following instructions in order to submit attachments for one or more FinCEN SAR within
their batch file:
1. Record the supporting document file name for each FinCEN SAR XML within the batch
Record the <ActivitySupportDocument> element, along with the <OriginalAttachmentFileName> sub-
element, for each FinCEN SAR Activity within the XML batch associated with an attachment. Record the full
name of the corresponding CSV file within the OriginalAttachmentFileName element.
2. Record the counts for the total number of attachments and FinCEN SAR XML activities with
attachments with the batch
Record the following attributes and counts within the EFilingBatchXML element in the XML batch:
ActivityAttachmentCount. The count of all <Activity> elements in the batch where the
<OriginalAttachmentFileName> element is recorded with a value referencing the file name of the
FinCEN SAR attachment
AttachmentCount. The count of all <OriginalAttachmentFileName> elements in the batch that
contain a value referencing the file name of the FinCEN SAR attachment
3. Include all attachments in a single zip file with the FinCEN SAR XML activity sequence number
appended to each attachment file name
Create a zip file composed of all attachments. When naming the zip file, be sure to use a descriptive
file name to help you identify which FinCEN SAR batch your attachment zip file is associated with.
For each csv attachment file within the zip file, append the corresponding sequence number (i.e.
“SeqNum” value associated with the FinCEN SAR Activity in the XML batch as follows:
<FinCEN SAR Activity SeqNum>_<OriginalAttachmentFileName>.csv
For example:
1_BankofUSBatchAttachment.csv
The above example indicates that within the FinCEN SAR XML batch, Activity SeqNum=”1” contains
the <OriginalAttachmentFileName> element with the value of “BankofUSBatchAttachment.csv”.
4. Attach the attachments zip file to the FinCEN SAR XML Batch Form prior to submission
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Once all required fields are complete and your FinCEN SAR XML batch has been attached to the FinCEN SAR
XML Batch Form, locate the Add File button for attachments in order to add your attachment zip file to the
FinCEN SAR XML Batch Form. Once the attachment file is attached, you may sign the FinCEN SAR Batch Form
with your PIN, save, and submit.
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