FinCEN Proposes SAR Information Sharing Pilot Program

The Financial Crimes Enforcement Network today issued a notice of proposed rulemaking to establish a pilot program for financial institutions to share suspicious activity reports with their foreign branches, subsidiaries and affiliates.

The limited-duration pilot program would expand the sharing of suspicious activity reports from previous guidance, which stated that the reports may only be shared internally with foreign head offices, controlling companies and domestic affiliates.

FinCEN said it expects the pilot program to provide valuable feedback as it considers longer-term approaches toward SAR sharing with foreign affiliates. The notice of proposed rulemaking seeks comment on establishing the pilot program, including input on the expected costs and benefits, technical challenges, the merits of quarterly reporting and how to protect SAR confidentiality. Comments will be due on March 28.

“ABA has long supported SAR information sharing between banks, and we look forward to working with FinCEN and our members to help make the new pilot program a success,” the American Bankers Association said. “Although important steps must be taken to maintain SAR confidentiality, we believe the program will make it easier and more efficient to fight fraud and illicit finance while allowing banks to better manage enterprise-wide risk.”

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