Co-authored by Linda Noonan
On January 14, 2003, the Department of the Treasury ("Treasury"), Financial Crimes Enforcement Network ("FinCEN"), sent to the Federal Register the expected proposed amendment to the Bank Secrecy Act ("BSA") regulation which would require mutual funds to file suspicious activity reports ("SARs") on the special form designed for the securities and futures industries, known as an "SAR-SF." The proposed rule is very similar to the SAR requirements for securities broker-dealers published on July 1, 2002. 67 Fed. Reg. 44068. Comments must be filed within 60 days after publication in the Federal Register.
Background
This proposal should be read in conjunction with Treasury's interim final rule published on April 29, 2002, which requires mutual funds to develop and implement anti-money laundering programs under section 326 of the USA PATRIOT Act as of July 25, 2002 (76 Fed. Reg. 21117), and the proposed Treasury and Securities and Exchange Commission ("SEC")
