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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.

88 minutes
Course Exam
Certificate of Completion
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Why Lorman?

Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Agenda

The Bank Secrecy Act (BSA)

  • Overview of the BSA
  • Anti-Money Laundering (AML) Program Requirement
  • Reporting Requirement

The Suspicious Activity Report (SAR) Filing Requirement

  • History of the SAR Filing Requirement
  • When Are SAR Filings Required?
  • How Quickly Do SARs Need to Be Filed?

FinCEN Form 111

  • How to File SARs With FinCEN
  • What Information Is Contained on the SAR Form?
  • How to Write Effective SAR Narratives

SAR Confidentiality

  • Disclosing to FinCEN and Law Enforcement
  • Disclosing Within the Corporate Organizational Structure
  • Recent Enforcement Actions

SARs: Current Issues

  • Recent FinCEN Guidance and FAQs
  • FinCEN Data Breach
  • New Legislation: AML Act
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Why Lorman?

Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Credits

OnDemand Course

Applications have not yet been submitted for Delaware, Idaho, Kentucky, Maine, Ohio, Oklahoma, South Carolina, and Wyoming CLE for this course. However, if you are interested in obtaining CLE for any of the listed states or have any additional credit questions please email us at [email protected] or call us at 866-352-9540.

This course was last revised on March 23, 2021.

Call 1-866-352-9540 for further credit information.

  • AK CLE 1.5
     
  • Alaska attorneys may receive 1.5 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
     
  • AL CLE 1.5
     
  • This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.5 hours credit.
     
  • AR CLE 1.5
     
  • This course has been approved for 1.5 hours of CLE by the Arkansas CLE Board.
     
  • Arizona CLE 1.5
     
  • The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.5 hours toward your annual CLE requirement for the State Bar of Arizona.
     
  • CA MCLE 1.5
     
  • Lorman Business Center, LLC. is a State Bar of California approved MCLE sponsor and this course qualifies for 1.5 CLE hours of participatory credit.
     
  • CT CLE 1.0
     
  • Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
     
  • HI CLE 1.25
     
  • This program was approved by the Hawaii State Board of Continuing Legal Education for 1.25 CLE credit hours.
     
  • IL CLE 1.25
     
  • This course was approved for a total of 1.25 hours of MCLE Credit by the Illinois MCLE Board.
     
  • ND CLE 1.5
     
  • North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.5 hours of CLE credit.
     
  • NH MCLE 1.5
     
  • NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 88 Minutes.
     
  • NJ CLE 1.8
     
  • This program has been approved by the Board on Continuing Legal Education of the Supreme Court of New Jersey for 1.8 hours of total CLE credit.
     
  • PA CLE 1.0
     
  • This Distance Learning program has been approved by the Pennsylvania Continuing Legal Education Board for 1.0 hours of substantive law, practice and procedure CLE credit.
     
  • RI CLE 1.5
     
  • This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.5 hours of CLE credit.
     
  • VT CLE 1.5
     
  • This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.5 hour(s) of CLE credit. Please note: Attorneys may only claim 6 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
     
  • WI CLE 1.5
     
  • This program qualifies for 1.5 hour(s) of ondemand CLE through the WI Board of Bar Examiners.
     
  • WV MCLE 1.8
     
  • This program has been approved by the West Virginia State Bar MCLE Commission for 1.8 MCLE hours.
     

To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

MP3 Download

  • Arizona CLE 1.5
     
  • CA MCLE 1.5
     
  • HI CLE 1.25
     
  • NJ CLE 1.8
     
  • VT CLE 1.5
     
  • WV MCLE 1.8
     
The CLE Code is ONLY a requirement when applying for CLE Credit in California (for participatory credit), Kansas, New Jersey or New York. Other states do not need to supply the CLE Code to apply for CLE credit.

This program does NOT qualify, nor meet the National Standard for NASBA accreditation.

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Why Lorman?

Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

Faculty

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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Why Lorman?

Over 34 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.

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Product ID: 407283
Published 2021
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