Tag Archives: Suspicious Activity Reports (SARs)

Federal Agencies Jointly Release Responses to FAQs on SARs and Other AML Considerations

On January 19, 2021, the Federal Reserve Board, FDIC, OCC, FinCEN, and NCUA (collectively, the “federal agencies”) issued answers to frequently asked questions (“FAQs”) regarding suspicious activity reports (“SARs”) and other anti-money laundering (“AML”) considerations for financial institutions subject to SAR requirements in response to recent recommendations from the Bank Secrecy Act Advisory Group. The … Continue Reading

New U.S. AML Legislation – Five Provisions for Foreign Banks to Watch

On January 1, 2021, the United States Congress enacted the Anti-Money Laundering Act of 2020 (the “AMLA”), as part of the National Defense Authorization Act (the “Act”).  The AMLA includes extensive and fundamental reforms to anti-money laundering (“AML”) laws in the United States, including the Bank Secrecy Act (“BSA”). In a previous client alert, we … Continue Reading

BSA/AML Reform in the 2021 NDAA Becomes Law

On January 1, 2021, the Senate voted to override President Trump’s veto of the National Defense Authorization Act (the “NDAA” or “Act”), which includes over 200 pages of significant reforms to the Bank Secrecy Act (“BSA”) and other anti-money laundering (“AML”) laws that have been working their way through Congress for several years.  The Senate’s … Continue Reading

CFPB Releases Report on Elder Financial Abuse

On February 27, 2019, the CFPB announced the release of a report identifying key facts, trends, and patterns in elder financial exploitation and abuse.  The Bureau’s report is based on an analysis of 180,000 Suspicious Activity Reports (“SARs”) filed with the Financial Crimes Enforcement Network (“FinCEN”) by banks, credit unions, and other financial services providers … Continue Reading

Senate Testimony Highlights Tensions in BSA/AML Reform Efforts as Lawmakers Consider Bipartisan Legislation

Representatives of the Office of the Comptroller of the Currency (“OCC”), the Financial Crimes Enforcement Network (“FinCEN”), and the Federal Bureau of Investigation (“FBI”) testified on Thursday, November 29 before the Senate Committee on Banking, Housing, and Urban Affairs (“Banking Committee”) on anti-money laundering (“AML”) issues. The testimony highlighted some tensions between the views of … Continue Reading

FinCEN Issues Advisory on Suspicious Activity Reporting Requirements for Cyber-attacks Under the Bank Secrecy Act

On October 25, 2016, the Financial Crimes Enforcement Network (FinCEN) issued an Advisory to financial institutions to (i) clarify reporting requirements under the Bank Secrecy Act (BSA) for filing Suspicious Activity Reports (SARs) on cyber-attacks and cyber-enabled crimes, (ii) note what information financial institutions should include in such reports, and (iii) encourage financial institutions to share … Continue Reading
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