Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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4/25/2005 USA PATRIOT Act Monitor News Release: National Security Letters Do Not Automatically Require SAR filings

A financial institution's receipt of a National Security Letter from the FBI does not automatically require the filing of a Suspicious Activity Report, according to the 8th SAR Activity Review. Nevertheless, the Letter should enter into the institution's risk assessment of related customers and accounts, which with other information may result in the filing of a SAR. If a SAR is filed, the form, including the narrative, should make no reference to the receipt of existence of the Letter. FinCEN's position on Letters is consistent with an interpretive letter the OCC issued in 2004. FinCEN's position will be discussed in detail in a forthcoming issue of the Monitor and a new section on National Security Letters is being added to Money Laundering, Terrorism and Financial Institutions.

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