Knowing When to File: SAR Decision-Making Tips for MSBs—and Why Expert Guidance Matters

Suspicious activity is a fact of life for Money Services Businesses (MSBs). Whether you’re operating a check cashing store, money transmitter, or multi-service MSB, odds are you’ve encountered customers, transactions, or patterns that just don’t sit right. But recognizing something as “unusual” or “questionable” is only half the battle. The real challenge lies in knowing when that activity crosses the line and compels a Suspicious Activity Report (SAR) filing under the Bank Secrecy Act (BSA).

While the law gives MSBs some discretion, the standard of “knows, suspects, or has reason to suspect” can be maddeningly vague. In an environment where regulatory scrutiny is increasing and enforcement actions are costly, this is not an area where you can afford guesswork or gut decisions. And yet, far too many MSBs struggle to build reliable systems—and internal confidence—for determining when SAR filing is necessary.

That’s where practical tips and the support of a qualified third-party compliance consultant can make all the difference. Below, we offer guidance for navigating this murky terrain, along with reasons why leaning on expert help could be one of the smartest compliance decisions you make.

Tip 1: Define “Suspicious” with Context, Not Just Compliance Manuals

Every MSB should have a clear definition of suspicious activity in its AML/BSA compliance manual, and that definition should be in line with FinCEN guidance and regulatory expectations. But static definitions can’t keep up with the nuance and evolving patterns of real-world transactions.

A transaction may be “structured” to avoid reporting requirements. But was it intentional? Does the customer routinely split transactions across branches or dates? Is there a legitimate business reason, or are you witnessing evasion?

Context is critical. Knowing your customer (KYC) and maintaining up-to-date Customer Due Diligence (CDD) profiles helps you distinguish between activity that is unusual but explainable and activity that signals potential criminal intent.

A qualified compliance partner will train your staff to ask the right questions—internally and externally—to understand that context fully.

Tip 2: Don’t Rely on Dollar Thresholds Alone

One of the most common mistakes among MSB operators is focusing solely on transaction size when evaluating suspicious activity. Yes, certain thresholds (like the $3,000 cash transaction rule) require recordkeeping, and larger transactions often attract attention. But criminal behavior doesn't always come with a high dollar tag.

A customer cashing five $950 checks over 10 days may raise more red flags than one customer cashing a single $7,500 check on consecutive days—especially if the checks appear to be from unrelated sources, written sequentially, or linked to a high-risk industry.

Effective transaction monitoring systems should look for patterns over time, not just spikes in volume. But that’s only possible if the data is accurate and analyzed by someone who knows what to look for—like a compliance expert who sees hundreds of cases a year and recognizes what’s normal and what’s not.

Tip 3: Document Everything—Even When You Don’t File

Regulators don’t just care about what you report—they care about how you made the decision. If you spot potentially suspicious activity but decide not to file a SAR, you must be prepared to defend that decision later during a regulatory examination or law enforcement inquiry.

Maintain internal documentation of what was observed, who reviewed it, what conclusion was reached, and why. If you consulted a third party (which is advisable in gray areas), record their input too.

Not filing is sometimes the right call. But not being able to explain why you didn’t file is a recipe for trouble.

Tip 4: Use the 30-Day Window Wisely

The BSA requires MSBs to file a SAR no later than 30 calendar days after the date of initial detection of facts that may constitute a basis for filing. That doesn’t mean you have to file on day 1—but it also doesn’t mean you can wait until day 30 to start your analysis.

Use the early part of the window to gather supporting information, review past transactions, or consult a compliance professional. If you’re still unsure by day 20, it’s time to make a final decision.

If you do file, remember: more detail is better. A vague SAR isn’t helpful and may even trigger questions about the adequacy of your compliance program.

Tip 5: Leverage a Qualified Compliance Consultant—Before You’re in Over Your Head

This is the step too many MSBs overlook. You’re busy running your business. Your staff may be trained, but they’re not forensic analysts. You may have an AML software solution, but it only does what it’s told—and if your rules are off, so are your results.

A seasoned MSB compliance consultant brings a deep understanding of the BSA, experience with actual enforcement actions, and real-world insight into what regulators and banks expect. They’ve seen the traps, pitfalls, and gray areas that software won’t catch.

Here’s what a strong compliance partner can do:

• Help assess and validate suspicious activity.
• Offer independent judgment to reduce bias in internal decisions.
• Identify gaps in your current monitoring system and suggest updates.
• Guide you through the SAR narrative to ensure clarity and effectiveness.
• Review your compliance program and recommend improvements—before regulators spot the weaknesses.

But not just any consultant will do. It must be someone who understands the MSB industry, check cashing operations, and the nuances of financial crime risks specific to your business model. That’s why firms like ComplyCheck exist—not to scare you into over-filing, but to help you make informed, defensible decisions with confidence.

Why This Matters: Your Reputation—and Your Business—Is on the Line

Filing SARs isn’t just a regulatory duty. It’s also a matter of trust between your MSB and its banking partners, your customers, and the agencies that rely on your reports to fight financial crime.

Too many filings, and you look sloppy or afraid. Too few, and you look oblivious—or worse, complicit. A strong SAR program shows that you take compliance seriously, operate with integrity, and are engaged in protecting the financial system.

Remember, when a SAR is filed, it can lead to deeper investigations, subpoena requests, or future examinations. If your filings are inconsistent, incomplete, or unjustified, regulators may assume the rest of your program is equally weak.

On the flip side, a clean SAR filing history—where the decision-making is documented, reasoned, and occasionally supported by a third party—tells a different story. It signals maturity, competence, and readiness for whatever comes next.

Final Thoughts: When in Doubt, Don’t Guess—Ask an Expert

If you’re hesitating over whether to file, that’s a sign in itself. Don’t guess. Don’t make a decision based on fear of losing a customer or because you don’t want to “make a big deal” out of something. Get the facts, apply the standards, and if you’re unsure, consult someone who knows.

At ComplyCheck, we specialize in helping MSBs navigate these critical decisions. Our team includes former examiners, bankers, and experienced compliance officers who understand the real-world implications of SARs—and how to build defensible compliance systems that keep you operational, informed, and protected.

If you're facing SAR decision fatigue or want a second set of eyes on questionable activity, reach out. Because in the world of compliance, knowing when not to file is just as important as knowing when you must.

Ready for Clearer SAR Decisions?

Contact ComplyCheck today for expert guidance on suspicious activity, SAR filings, and building a compliance program you can stand behind—no guesswork required.