News & Analysis as of

Internal Investigations Suspicious Activity Reports (SARs)

A&O Shearman

U.S. Subsidiary Of Dutch Bank Pleads Guilty To Allegations That It Conspired To Obstruct OCC Examination Of AML Program

A&O Shearman on

On February 7, 2018, Dutch bank Rabobank’s U.S. subsidiary pleaded guilty to conspiring to impair, impede, and obstruct a review by the Office of the Comptroller of the Currency (“OCC”) of the bank’s anti-money laundering...more

Davis Wright Tremaine LLP

Protection Against Discovery of SARs and Related Internal Investigation Documents Given Resounding Endorsement by Washington State...

The Bank Secrecy Act prohibits financial institutions from producing Suspicious Activity Reports and documents related to internal monitoring and investigations that are intended to “detect fraud and money laundering.” The...more

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