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Suspicious Activity Reports: Reporting, Requirements and Current Issues


Understand the current requirements and regulatory expectations related to your suspicious activity filings.

Many financial institution employees are aware of the requirement to file suspicious activity reports (SARs) with the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) and the general notion that SARs are required to be kept confidential, but do not understand how or why SARs are used by law enforcement, what is required to be reported on them, how they are filed with FinCEN, and why they need to be kept confidential.
This material will help the persons involved in a financial institution's anti-money laundering (AML) compliance efforts understand these points, focusing most importantly on the bounds of SAR confidentiality. Financial institutions, and their directors, officers, employees, or agents that breach SAR confidentiality requirements may be subject to civil and criminal penalties; this information will assist individuals in understanding the requirements. This topic will also explore what the SAR filing requirement may look like in the future under the AML Act recently passed by Congress.



Melissa G. R. Goldstein

Melissa G. R. Goldstein

Schulte Roth & Zabel

  • Special Counsel, Schulte, Roth & Zabel's Washington D.C. office
  • Advises banks, broker-dealers, investment advisers, funds, insurance companies and money services businesses, including those involved in global e-commerce and virtual currency, on the anti-money laundering and sanctions regulations, rules and related issues governing their investment and business activities
  • Expertise with issues arising out of the USA PATRIOT Act, as amended by the Bank Secrecy Act
  • Frequent speaker on anti-money laundering related issues
  • Previous attorney-advisor with the U.S. Department of the Treasury‚Äôs Financial Crimes Enforcement Network (FinCEN) where she assisted in the development of anti-money laundering regulations and guidance, and served as counsel on enforcement actions involving issues such as failure to implement and maintain an adequate anti-money laundering compliance program, failure to register as a money services business, and failure to maintain confidentiality of suspicious activity reports
  • J.D. degree, Fordham University School of Law; B.S. degree, with honors, Cornell University
  • Can be contacted at 202-729-7471 or [email protected]
Nicholas Zlevor

Nicholas Zlevor

Schulte Roth & Zabel

  • Associate practicing in the Bank Regulatory Group at Schulte Roth & Zabel
  • Focuses on advising clients on compliance with federal and state banking and consumer finance laws, including multistate licensing requirements, as well as regulatory issues associated with payments products and services
  • Has experience advising financial services providers, including money transmitters and payment processors, and state and federally chartered depository institutions on regulatory and transactional matters

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