FinCEN Issues SAR Activity Review

The Financial Crimes Enforcement Network (FinCEN) has issued today its fourth SARActivity Review – Trends, Tips and Issues. This issue of The Review contains information related topotential terrorist financing activity as well as an analysis of SAR filings since September 11, 2001that referred to terrorism.The Review also provides an update of measures taken since the events of September 11ththat impact the identification of suspicious activity and the preparation and filing of SARs,including discussion of the expansion of anti-money laundering compliance requirements under theUSA PATRIOT Act. Guidance regarding SAR disclosures as part of civil litigation as well as aforum that offers insights on safe-harbor protection for employee references are also included forthe benefit of The Review’s primary audience--the financial services industry.The Review represents a vital, cooperative effort involving financial servicesrepresentatives, federal law enforcement and regulatory agencies. Included in the report are SARstatistics, patterns and trends of suspicious activity that have been reported, law enforcementinvestigations that were assisted by SAR information, tips and guidance for financial institutions onform preparation and filing, and an industry forum.“The SAR Activity Review serves as a key focal point in the continuing dialogue betweengovernment and the financial community,” said FinCEN Director James F. Sloan. “The financialcommunity has an important role to play in providing potentially useful lead information to lawenforcement and it is our job to ensure that our partnership works both ways. This is especially truein the post-9/11 context, when both the public and private sectors have ratcheted up their efforts toprevent terrorist access to our financial systems.”Financial institutions were required to begin filing SARs in April of 1996 to assist lawenforcement in detecting and prosecuting violations of money laundering and other financialcrimes. As the SAR program matured, feedback among law enforcement, regulators and theregulated industry about the value of the information being reported was recognized as an importantpart of on-going efforts to further refine the quality of SAR information.Among those that participated in this review were: the American Bankers Association;Independent Bankers Association; Independent Community Bankers of America; AmericanInstitute of Certified Public Accountants; Securities Industry Association; Non-Bank FundsTransmitters Group; Federal Reserve Board; Office of the Comptroller of the Currency; FederalDeposit Insurance Corporation; Office of Thrift Supervision; National Credit UnionAdministration; Federal Bureau of Investigation; U.S. Department of Justice’s Asset Forfeitureand Money Laundering Section; U.S. Department of Justice’s Criminal Division; U.S.Department of the Treasury’s Office of Enforcement; U.S. Customs Service; U.S. Secret Service;Internal Revenue Service; and Financial Crimes Enforcement Network.The Review will be available on FinCEN’s website today at www.fincen.gov