Davis Polk partner Dan Stipano was quoted in the American Banker, MoneyLaundering.com and the Wall Street Journal on FinCEN’s proposal to create a pilot program that would allow some U.S. banks to share suspicious activity reports (SARs) with their business units in other countries. The program aims to improve banks’ ability to combat money laundering.

Dan noted that internationally active banks and other financial institutions have for many years wanted to share SARs throughout their global enterprises, to help their anti-money laundering programs.

He told the WSJ, “Being able to effectively prevent and deter money laundering really depends heavily on being able to share information. If information is siloed…nobody has the full picture.”

He added, though, that some of the requirements in FinCEN’s proposal could be burdensome, and banks will need to weigh the burdens against the benefits of participating.

“Treasury Wants Banks to Loop in Foreign Affiliates on Suspicious Transactions,” Wall Street Journal (January 24, 2022) (subscription required)

“Banks back plan to share SARs with foreign units. For now.” American Banker (January 24, 2022) (subscription required)

“FinCEN Pitches Cross-Border Exchange of SARs,” MoneyLaundering.com (January 24, 2022) (subscription required)

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