Morgan Lewis

Impact of New FinCEN Regulations Concerning The Filing of Suspicious Activity Reports (SARs)

By David S. Mandel

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White Paper

  • published on:

    02/01/1996

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Bank Secrecy Act (BSA) regulations mandate that "[e]very bank shall file... a report of any suspicious transaction relevant to a possible violation of law or regulation." 31 CFR §103.21(a). On February 5, the U.S. Treasury Department's Financial Crimes Enforcement Network (FinCEN) unveiled a series of amendments to its rules requiring banks and other depository institutions to report suspicious transactions. All financial institutions that are supervised by the Federal Reserve Board, Office of the Comptroller of the Currency, Federal Deposit Insurance Corporation, Office of Thrift Supervision and the National Credit Union Administration are covered by and must comply with the new rules. They take effect, along with the new "Suspicious Activity Report" (SAR) form, on April 1.

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