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ARTICLE · 09 FEBRUARY 2022

What To Know About FinCEN's Proposed Pilot Program On SAR Sharing

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On January 24, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking (NPRM) pursuant to Section 6212(a) of ...

United StatesGovernment, Public Sector
Richard Alexander
Richard Alexander
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David Freeman, Jr.
Amber A. Hay
Amber A. Hay
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Michael Mancusi
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Kevin Toomey
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Christopher Allen
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Erik Walsh
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On January 24, 2022, the Financial Crimes Enforcement Network (FinCEN) issued a notice of proposed rulemaking1 (NPRM) pursuant to Section 6212(a) of the Anti-Money Laundering Act of 2020 (AML Act)2 for a pilot program that would permit financial institutions to share suspicious activity reports (SARs) and related information with their foreign branches, subsidiaries, and affiliates (foreign affiliates) 3 for the purpose of combatting illicit finance risks. Although the proposed rule would provide participating institutions with greater flexibility to share SARs internationally throughout their organizations, financial institutions will need to evaluate whether the benefits of the pilot program justify the additional compliance and reporting obligations.

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