Suspicious Activity Reporting (SAR) under the Bank Secrecy Act and Anti-Money Laundering: What You Need to Know About the Safe Harbor and Limitations to Immunity

Troutman Pepper
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This presentation will provide:

-Introduction to Suspicious Activity Reporting (SAR)

-Summary of Annunzio-Wylie Anti-Money Laundering Act, 31 U.S.C. § 5318(g)(3)(A)

-Split in authority regarding scope of safe harbor provision (absolute immunity vis-à-vis qualified immunity)

-Plain language of the Anti-Money Laundering Act, its legislative history, and public policy concerns.

-Legislative Fix

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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