Davis Polk partner Dan Stipano discussed with Anti-Corruption Report how financial institutions can navigate regulatory reporting rules pertaining to Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) and whether the monetary thresholds for these reporting rules are outdated.

“Law enforcement is adamantly opposed to any increase in the dollar thresholds for SARS or CTRs because they say that they need each and every one of these reports, and that even low dollar transactions could be related to more significant financial crimes,” Dan explained.

“Rethinking monetary thresholds and regulations,” Anti-Corruption Report (December 20, 2023) 

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