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FFIEC Updates Anti-Money Laundering Examination Manual

 

Suspicious Activity Reports

 

February 26, 2015
OVERVIEW
On December 2, 2014, the Federal Financial Institutions Examination Council (FFIEC) released an updated version of its Bank Secrecy Act/Anti-Money Laundering (BSA/AML) Examination Manual. Revisions were made throughout the manual. This Alert focuses on the changes to filing Suspicious Activity Reports (SARs).
CHANGES
1) SAR E-filing requirements.

2) Extends the time frame for SAR filing for continuing activity from 90 to 120 days to allow for a 90-day review of activity and an additional 30 days thereafter to file.

3) Clarifies prohibitions on disclosing a SAR to explain that it is appropriate in certain circumstances to share the underlying facts that prompted the SAR filing so long as that does not result in providing notice to any person involved in the suspicious activity that there was a report.

4) Provides guidance on sharing SARs with affiliates by including a definition of "affiliate" and other key terms.
SUGGESTED GUIDANCE
A) To extend to an additional 30 days to file a SAR on continuing activity, review and revise existing policies and procedures to conform to this change.

B) Review disclosure and sharing policies and procedures for consistency with the updated guidance.
Link

Banking organizations and credit unions should direct questions about the manual to their primary federal or state regulator.
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