FinCEN also gives instructions within the notice on SAR filing for crimes related to trade in antiquities and art. FinCEN requests that financial institutions:

• Reference “FIN-2021-NTC2” in SAR field 2 (Filing Institution Note to FinCEN) and the narrative portion of the SAR to indicate a connection between the suspicious activity being reported and the activities highlighted in this notice
• Select SAR field 36(z) (Money Laundering - other) as the associated suspicious activity type, and note if the suspicious activity relates to “Antiquities,” “Art,” or both
• Include in the SAR narrative how the suspicious activity relates to antiquities or art by providing details including:
  • the objects are connected to the suspicious financial transactions and any other related transactions
  • names, identifiers, Internet Protocol (IP) address, and phone numbers of the purchasers or sellers of the property and their intermediaries or agents
  • the volume and dollar amount of the transactions involving the dealer in antiquities or art
  • any beneficial owners of entities involved
  • in the case of stolen art or antiquities, provide a detailed and specific description of the stolen item(s) and indicate whether photographs of the items are available.
  • information about the place(s) where the reported individuals or entities are operating

This is the first of many steps FinCEN must take to satisfy and implement the requirements of the Act, and financial institutions should remain diligent in updating policies, procedures, and processes as regulations and guidance unfolds. Being proactive and informed of the sweeping changes expected within the AML industry, will result in a stronger BSA program ready to face a more modernized and streamlined future.