Introductory BSA/AML Examiner School, Providence, RI

Suspicious Activity Monitoring Prohibition of SAR Disclosure

• No bank, and no director, officer, employee or agent of a bank that reports a suspicious transaction may notify any person involved in the transaction that a SAR was filed. Safe Harbor from Civil Liability • Federal law (31 USC 5318(g)(3)) provides protection from civil liability for all reports of suspicious transactions made to appropriate authorities. . . • Applies to the bank, its directors, officers, employees and agents that make reports to appropriate authorities.

Suspicious Activity Monitoring Days to File • 30 days from initial detection if the suspect can be identified. • 60 days from initial detection if no suspect can be identified.

The board should be notified of the SAR filing at it next meeting subsequent to the filing.