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FinCEN › Suspicious Activity Reports (SARs) › Banking Sector

The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of... more +
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury charged with detecting and combatting illegal activity within the financial system. FinCEN detects evidence of money laundering, terrorist financing and other financial crimes by collecting, monitoring, and analyzing financial transaction data. Such data is disseminated to both domestic and international law enforcement agencies. less -
Jenner & Block

Client Alert: A Second Wave: FinCEN and SEC Further Extend Investment Advisers’ AML Obligations with New CIP Requirements

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In a sequel to FinCEN’s proposal earlier this year to extend anti-money laundering and Bank Secrecy Act regulations to investment advisers (AML/BSA Proposal), on May 13, 2024, FinCEN and the SEC jointly issued a new Notice of...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2023

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A recent OCC report identified key issues facing the federal banking system, including increasing credit risk due to higher interest rates, increasing risk in commercial real estate lending, prolonged inflation, declining...more

Holland & Knight LLP

Twinkle-Twinkle Little SAR: SEC & FINRA Settle with Broker-Dealers and Registered Rep

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In a series of settlements announced this year, the U.S. Securities and Exchange Commission (SEC) and the Financial Industry Regulatory Authority (FINRA) penalized several broker-dealers for allegedly failing to file...more

Troutman Pepper

FinCEN Warns of Surging Check Fraud

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On February 28, the Financial Crimes Enforcement Network of the U.S. Department of Treasury (FinCEN) issued an alert warning financial institutions to be vigilant in identifying and reporting check fraud schemes targeting the...more

Ballard Spahr LLP

Real Estate and Money Laundering: FinCEN Issues Advanced Notice of Regulations for the Real Estate Industry

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On December 6, FinCEN announced that it was issuing an Advanced Notice of Proposed Rulemaking (“AMPRM”) to solicit public comment on potential requirements under the Bank Secrecy Act (“BSA”) for certain persons involved in...more

White & Case LLP

Winning the AML Intelligence War with Public Private Partnerships

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Key considerations for banks engaging with governments and peer institutions to improve financial crime compliance systems - Every year, banks spend billions of dollars on core financial crime compliance systems and are...more

Nutter McClennen & Fish LLP

Nutter Bank Report: October 2021

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Federal and State Financial Regulators Publish New Guidance on LIBOR Transition - The federal banking agencies, the NCUA and the CFPB, in conjunction with the state bank and state credit union regulators, have issued joint...more

Goodwin

Federal Agencies Issue Joint Statement on Management of LIBOR Transition

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In This Issue. Federal agencies issued a joint statement regarding an orderly transition away from the London Interbank Offered Rate (LIBOR); the Office of the Comptroller of the Currency (OCC) issued an updated...more

Eversheds Sutherland (US) LLP

FinCEN on fire: Rapid release of AML Act updates

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On June 30, 2021, the Financial Crimes Enforcement Network (FinCEN) provided an update on implementation of the Anti-Money Laundering Act of 2020 (AML Act) and issued the first government-wide priorities for anti-money...more

Holland & Knight LLP

FinCEN Announces National AML/CFT Policy Priorities

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The Financial Crimes Enforcement Network (FinCEN) on June 30, 2021, issued national priorities for anti-money laundering (AML) and countering the financing of terrorism (CFT) policy (the Priorities), as required by the...more

Ballard Spahr LLP

Banking and Cannabis Enforcement Round Up:  NCUA Imposes First Penalty Relating to Cannabis Banking Services; Cannabis Industry...

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Much has occurred in the last two months regarding the relationship between financial institutions and Marijuana-Related Businesses, or MRBs. In this post, we discuss three major developments, all of which share a complex...more

Jones Day

2020 Anti-Money Laundering Year in Review

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2020 witnessed a flurry of anti-money laundering activity, with the issues and developments continuing to be global in scope. In the United States, suspicious activity reports, outlining transactions involving terrorism...more

Goodwin

Biden Administration Issues Regulatory Freeze On New Agency Rules

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In this Issue. In one of its first acts after being installed on January 20, the Biden Administration issued a regulatory freeze on new agency rules that have been adopted but are not yet effective; in one of its final acts...more

Ballard Spahr LLP

FinCEN and Other Federal Banking Agencies Provide Much-Needed Guidance on Suspicious Activity Reports

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SARs Do Not Need to Be Filed At the First Sign of Potential Problems - Honoring “Keep Open” Letters from Law Enforcement Should Not Lead to Criticism - On January 19, 2021, the Financial Crimes Enforcement Network...more

Ballard Spahr LLP

The OCC Embraces Technology, Proposes Exemption to SAR Requirements and Announces Acceptance of Distributed Ledgers and...

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The Comptroller of the Currency (the “OCC”) has been busy, and focused on technology. We discuss two recent developments: proposed regulations that would allow the OCC to grant exemptions relating to Suspicious Acivity...more

Thomas Fox - Compliance Evangelist

Major Changes in AML Compliance and Enforcement: Part 1-Introduction to the Anti-Money Laundering Act of 2020

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2020 was a most significant year in anti-corruption enforcement; from Airbus to Goldman Sachs and numerous matters in between. Further there were two significant pieces of information from the US government in the form of the...more

Nutter McClennen & Fish LLP

Nutter Bank Report: December 2020

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FDIC Modernizes Brokered Deposit Rule and Amends Interest Rate Restrictions - The FDIC has adopted a final rule that establishes new standards for determining whether deposits made through certain kinds of arrangements...more

Ballard Spahr LLP

Massive BSA/AML Reform Legislation Released by U.S. House and Senate Committees for Passage — But Still Subject to Potential...

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On December 3, the U.S. House and Senate Armed Services Committees reached an agreement on the National Defense Authorization Act (“NDAA”), an annual defense spending bill. Within this huge bill (well over 4,500 pages) are...more

Ballard Spahr LLP

Regulatory Round Up: FinCEN Solicits Comments on Due Diligence for Correspondent and Private Bank Accounts

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Final Post in a Three-Post Series Regarding Recent Regulatory Action by FinCEN - On September 29, 2020, the Financial Crimes Enforcement Network (“FinCEN”) published a request for comment on existing regulations regarding...more

Alston & Bird

FinCEN Signals BSA/AML Regulatory Reform

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The Financial Crimes Enforcement Network takes the first of likely many steps to reform the outdated Bank Secrecy Act / Anti-Money Laundering regulatory scheme. Our Financial Services & Products and White Collar, Government &...more

White & Case LLP

Hemp Businesses and Financial Institution Due Diligence

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On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) issued guidance explaining how financial institutions can conduct due diligence for hemp-related businesses and identifying the type of information and...more

Ballard Spahr LLP

Cyber-Enabled Financial Crime and Money Laundering

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Today we are very pleased to welcome guest blogger Moyara Ruehsen, PhD, CAMS, CFCS, who is an Associate Professor and Director of the Financial Crime Management Program at the Middlebury Institute of International Studies in...more

Sheppard Mullin Richter & Hampton LLP

Clearing the Air: FinCEN Guidance May Help Banks Find Their Way in the Field of Hemp Financing

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On June 29, 2020, the Financial Crimes Enforcement Network (FinCEN) published updated guidance intended to “enhance the availability of financial services” for the hemp industry (the Guidance). Even though the Agriculture...more

Ballard Spahr LLP

The Banking of Cannabis and Hemp-Related Customers: An Update

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We are really pleased to presenting on July 9, 2020 to the National Association of Federally-Insured Credit Unions (“NAFCU”) on banking issues relating to cannabis. The cannabis and hemp industry continues to pose a...more

Eversheds Sutherland (US) LLP

Federal agencies clarify SAR filing requirements for financial services provided to hemp-related businesses

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On December 3, 2019, four federal agencies, in consultation with state banking regulators, clarified the legal status of hemp growth and production under the Bank Secrecy Act (BSA) for banks providing financial services to...more

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