FinCEN Automated E-Filing in Green Check

Setup Guide & FAQs

Green Check supports automated electronic filing of SARs and CTRs directly to FinCEN. This guide explains what automated e-filing is, what stays the same, and what you need to do now to get set up.

What is automated FinCEN auto-filing?

Automated FinCEN auto-filing allows you to securely transmit approved SAR and CTR batch files directly to FinCEN using Secure Direct Transfer Mode (SDTM) via SFTP without leaving Green Check.

This replaces manual XML uploads through the FinCEN BSA E-Filing portal while maintaining full compliance, oversight, and auditability.

What are the benefits?

• Eliminates manual uploads to FinCEN

• Reduces operational and administrative overhead

• Automatically retrieves FinCEN acknowledgment files

• Maps BSA IDs back to filings in Green Check

• Maintains a complete audit trail inside the platform

Who is the filing institution of record?

You are. Your financial institution remains:

• The filing organization of record

• Fully responsible for review, approval, and compliance

• The owner of all filings and acknowledgments

Green Check acts only as a secure technology transmitter on your behalf.

How does Green Check submit filings to FinCEN?

Green Check uses FinCEN-issued SFTP credentials that belong to your institution.

• Credentials are issued directly by FinCEN

• Credentials are unique to each financial institution

• Green Check does not use shared or platform-level credentials

• Credentials are stored securely and used only for transmitting your filings

What credentials are required?

To enable automated e-filing, your institution must have:

• FinCEN Secure Direct Transfer Mode (SDTM) / SFTP access enabled

• SFTP connection details and username issued by FinCEN

If you do not already have SDTM/SFTP access, you’ll need to request it from FinCEN.

Step 1: Request SFTP access through FinCEN’s BSA E-Filing system

To enable automated FinCEN e-filing in Green Check, your institution must have SDTM / SFTP access enabled directly by FinCEN.

FinCEN now supports SFTP-only connections for SDTM data transfers, so this step is required even if you’ve used other submission methods in the past.

How to request access

1. Go to the official FinCEN BSA E-Filing website and click "Help"

2. Open the Help Ticket Form (https://bsaefiling.fincen.gov/help-ticket)

3. Select the category: Secure Data Transfer (SFTP)

4. In your request, indicate that your institution needs to establish or transition to an SFTP account for SDTM batch submissions

This request is typically handled by your BSA, AML, or compliance team.

Step 2: Receive credentials from FinCEN

Once FinCEN processes your request, they’ll provide:

• SFTP connection details

• An SFTP username (and any additional setup instructions)

Timing can vary, which is why we recommend starting this step as soon as possible.

Step 3: Send credentials securely to Green Check

After receiving credentials from FinCEN, please send them to Green Check using your institution’s existing secure email system.

We’ll confirm receipt and take it from there.

What happens after that?

Once credentials are received, Green Check will:

• Configure secure transmission for your institution

• Support optional testing and validation

• Notify you when automated filing is ready to be enabled

From there, filings continue to be prepared, reviewed, and approved in Green Check. The submission step is simply automated.

• SARs and CTRs continue to be prepared, reviewed, and approved in Green Check

• Approved filings are transmitted automatically once reports are completed/filed

• FinCEN acknowledgment files are retrieved and stored

• BSA IDs are mapped back to filings for audit and tracking

What stays the same?

• Your internal review and approval workflows

• Filing ownership and regulatory responsibility

• Visibility into filings, acknowledgments, and audit history

• Control over when filings are submitted