Filing A Suspicious Activity Report ("SAR")

Filing A Suspicious Activity Report (“SAR”)

The Financial Crimes Enforcement Network requires certain financial institutions to file a Suspicious Activities Reports (“SAR”) to report suspicious transactions, as detailed in their FinCEN SAR Electronic Filing Instructions. This blog will go over some of the important aspects of filing a Suspicious Activity Report.

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AML and Branch Audits

AML and Branch Audits in the Time of COVID-19

At the beginning of the year, FINRA released important updates related to supervision requirements for broker-dealers. As broker-dealers and their employees started experiencing various work-from-home, virtual meeting, and operations challenges, FINRA provided valuable guidance for the transition in a FAQ related to the coronavirus pandemic. Below are a few items where FINRA has provided areas of relief related to AML and Branch audits. AML Independent Testing FINRA Rule 3310, Anti-Money Laundering (“AML”) Compliance Program, requires firms to perform independent testing of their AML program every calendar year. If a member firm neither executes transactions for customers, holds customer accounts, nor Read more about AML and Branch Audits in the Time of COVID-19[…]

FinCEN 314(a)

FinCEN 314(a) Program FAQs

The Financial Crimes Enforcement Network (FinCEN) is a service driven by law enforcement agencies to coordinate with covered financial institutions to help locate financial assets and transactions by subjects of criminal investigations, such as tax fraud or money laundering investigations. FinCEN is also a bureau of the U.S. Treasury Department. But did you know that FinCEN has multiple programs and broker-dealers are required to participate in the 314(a) program? Read More…

AML and Suitability

AML and Suitability Challenges During COVID-19

FINRA Rule 3310 provides broker-dealer guidance on how to design, test, and enforce a firm’s Anti-Money Laundering Program (“AML”). One main element of AML is to “establish and implement policies and procedures that can be reasonably expected to detect and cause the reporting of transactions required under 31 U.S.C. 5318(g) and the implementing regulations thereunder.” FINRA Notice to Members 19-10 identified a key list of red flags that may be used to help identify suspicious activity in trading, money movements, insurance, and securities.

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Top 6

Our Top Six Most Popular Blog Posts

MasterCompliance continues to provide clients and the public with guidance on industry focus areas, new rules, compliance foundations, and regulatory priorities. This blog explores our top six most popular blog posts.

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