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Suspicious Activity Detecting, Investigations, Monitoring, and Reporting

The detection, investigation, monitoring and reporting of suspicious activity and transactions should be at the very center of any firm’s anti-money laundering (AML) program.

Since 1996, all U.S. banks and banking firms (and, since 2002, their subsidiaries (e.g. broker-dealers, money transmitters, insurance)) have been required by federal law to provide financial regulators and law enforcement with referrals regarding possibly suspicious customer transactions (money laundering, structuring, check fraud, loan fraud, computer intrusion, terror financing) and insider/employee frauds (defalcation, embezzlement, mysterious disappearance, misuse of position).

This responsibility has been especially challenging because for many years there were no common definitions or standards, and no detailed instructions on when and how to file SARs. Also, there have been mixed signals on “detection,” the proper trigger events on SAR filing, as well as the possible consequences to the company for filing a SAR in error.

CRI’s expertise can be invaluable in supporting your Board of Directors, financial and legal advisers in the myriad decisions surrounding SAR filing.