Secure Direct Transfer Mode
Connection and file transfer requirements between BSA Direct E-Filing and filing
organizations using the Secure Direct Transfer Mode (SDTM).
FinCEN recommends the use of CONNECT:Direct Secure+ as the mechanism
for transferring files between BSA Direct E-Filing and any filing organization. This
type of transmission will work with the use of a server certificate on each server
to ensure mutual authentication between the 2 servers. It will be expected that
each side will perform a push of the file from their server to the other.
Any filing organization that wishes to use the SDTM to transmit their batched
submissions will need to contact the FinCEN Adminstrator
If your organization is not currently registered with the BSA E-Filing system, a User
ID will need to be acquired. To request a User ID go to the BSA
Direct E-Filing public web page (
http://BSAefiling.fincen.treas.gov/) and fill out the
Supervisory User Application Form. Once your application is received, FINCEN
will perform a vetting process on your organization and then issue you a User ID
to access the BSA E-Filing system. Once your User ID has been issued, you will
be assigned a Filing Organization Code (FO code) for your Organization.
Each side must have a version of CONNECT:Direct Secure+ using Triple
DES with TLS protocol installed on the server
Prepare private key through the CONNECT:Direct interface and obtain a
server certificate
Install server certificate for server identification and authentication
Data files to be pushed using Secure+ between servers
The files are to follow the prescribed naming standard
There is a file naming convention proposed which will help in the processing of
these files.
1) submission type – This needs to indicate the type of batch file
being placed onto the server (i.e. CTRST, SARST…).
2) Date/Time – This will be a date-time stamp to guarantee
filename uniqueness
o year – YYYY
o month – MM
o day – DD
o hour – hh
o minute – mm
o second – ss
3) organization naming – set aside for custom naming by
an organization.
Example file name: CTRST.20050609153015.REGION6
Filing Organization
C:D Secure+
C:D Secure+
BSA E-Filing
System
Java Process
DCC
FTP Mega
Batch File
FTP
Acknowledgement File
Send Batch
Files via
Secure+
Mega Batch
Process
Mega
Acknowledgeme
nt Process
BSA Direct E -Filing Server
SDTMServer
Send
Acknowledgement
Files via Secure+
Internet
«utility»
RSync
«utility»
RSync
Figure 1 Secure Direct Transfer Mode Architecture
Figure 2 Front-end Processing
Both filing organizations and the BSA Direct E-Filing (BSA E-Filing) system will
install and use a Sterling Commerce product for file transfers.
- Connect:Direct Secure+
Filing organizations and the BSA E-Filing system will always push files they
create.
Batch files will be transferred via a secure connection.
The SDTM server will kick off a process through the file agent or from a
RUNTASK initiated by the sender.
- Populate a form using data in the transferred batch files.
- Provide an affidavit and a place to add a digital signature on the form
- Attach the transferred batch file to this form.
- Submit the form into the BSA E-Filing system
BSA E-Filing
System
DCC
FTP Mega
B a tch F ile
FTP
Acknowledgement File
Mega Batch
Process
Mega
Acknowledgement
Process
BSA Direct E-Filing Server
«u tility »
u tility1
Figure 3 Back-end Processing
A confirmation email will be generated and sent to the filing organization’s user
containing:
- Process id
- Status information
A process will be run once a day that goes through all the submissions received
in the last 24 hours and pulls them together into a Mega Batch file to be sent to
DCC.
A work list will be defined inside BSA E-Filing that will list all of the received
batched files from the organization. These forms will remain in the system for 30
days Users will be able to access a work list to add their signature, print or save
the forms. The process ids for these forms will also appear in a Track Status
work list for tracking purposes.
DCC will send a Mega Acknowledgement file back to the BSA Direct E-Filing
system as they do today. The organization's acknowledgement data will be
parsed out of the returned Mega Acknowledge file to separate files and placed on
the SDTM Server. The Acknowledgement files will be pushed back to the
organization via Connect:Direct Secure+ and a RUNTASK will notify the
receiving server that the acknowledgements have been transferred.
An email notice will be sent to one selected organization user indicating their
acknowledgements are on their server and ready to be picked up.