On Thursday, March 28, 2013, the Financial Crimes Enforcement Network (FinCEN) issued a notice (the “Notice”) to financial institutions reminding them they must begin using the new FinCEN reports (i.e., SARs, CTRs, RMSBs and DOEPs), which are available only electronically through the Bank Secrecy Act (“BSA”) E-Filing System, by April 1, 2013.

FinCEN’s new SAR, CTR, RMSB, and DOEP reports have been available for use through the E-Filing System since March 29, 2012, and FinCEN has indicated that it will continue to accept submissions of the legacy versions of the SAR, CTR, DOEP, and RMSB only until March 31, 2013.

According to the Notice, financial institutions that continue to file mandated reports in paper format will fail to meet BSA reporting requirements and may be subject to civil money penalties.

Moreover, after March 31, 2013, FinCEN may reject any mandated reports filed in paper format and return them to the filing institution.

As a result of the foregoing, financial institutions may need to update and revise existing policies and procedures with respect to the filing and submission of electronic reports.

Read a copy of the Notice on E-Filing Mandate.

For more information regarding the Notice or the BSA E-Filing System, please contact Clemente Vazquez-Bello, Andres Fernandez or Gabriel Caballero of Gunster’s banking and financial services practice group.

This publication is for general information only. It is not legal advice, and legal counsel should be contacted before any action is taken that might be influenced by this publication.

Established in 1925, Gunster is one of Florida’s oldest and largest full-service law firms. The firm’s clients include international, national and local businesses, institutions, local governments and prominent individuals. Gunster maintains its presence in Florida with offices in Fort Lauderdale, Jacksonville, Miami, Orlando, Palm Beach, Stuart, Tallahassee, Tampa, The Florida Keys, Vero Beach and its headquarters in West Palm Beach. Gunster is home to more than 160 attorneys and 200 committed support staff, providing counsel to clients through 18 practice groups including banking & financial services; business litigation; construction; corporate; environmental & land use; government affairs; health care; immigration; international; labor & employment; leisure & resorts; private wealth services; probate, trust & guardianship litigation; professional malpractice; real estate; securities and corporate governance; tax; and technology & entrepreneurial companies. Gunster is ranked among the National Law Journal’s list of the 250 largest law firms.

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