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News Releases
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.
USA PATRIOT ACT MONITOR is published by Civic Research Institute, Inc., 4478 U.S. Route 27, P.O. Box 585, Kingston, NJ 08528, 609-683-4450, info@civicresearchinstitute.com, as an update service for Money Laundering, Terrorism and Financial Institutions: Law · Regulation · Compliance · USA PATRIOT Act Monitor © 2004 Civic Research Institute, Inc. All rights reserved. Unauthorized copying expressly prohibited. The information in this publication is not intended to replace the services of a trained legal professional. Neither the editors, nor the contributors, nor Civic Research Institute, Inc. are by this publication engaged in rendering legal, accounting, or other professional services. The editors, contributors, and Civic Research Institute, Inc., specifically disclaim any liability, loss, or risk, personal or otherwise, which is incurred as a consequence, directly or indirectly, of the use or application of the contents of this publication.