Gunster – Banking and Financial Services, April 2009
The Government Accounting Office (GAO) has issued a report to Congress responding to the latter’s request that the GAO examine a number of issued related to suspicious activity reporting. Specifically, the GAO Report examined (1) the underlying factors that affected the number of SARs filed by depository institutions from 2000 to 2007;(2) the actions that federal agencies have taken toimprove the usefulness of SARs for lawenforcement; (3) the ways in which federal agencies use SARs and actions they have taken to make better use of them; and (4) whether the process FinCEN uses to revise the SAR Form is effective in assuring that information collected is appropriate for law enforcement needs. In addition to addressing the questions and issuesdescribed above, the GAO Report, in varying degree, also touches upon the following interesting points:
● Defensive SAR filings
● Use of SAR Review Teams by federal lawenforcement and DOJ’s National SAR ReviewTeam
● The delay in the issuance of a new SARForm
* * *
Should you wish to receive further informationconcerning matters discussed in this publication,please contact:
Clemente L. Vazquez-Bello 305.376.6082 ▪ [email protected]
Andres A. Fernandez 305.376.6097 ▪ [email protected]
Marina Olman 305.376.6069 ▪ [email protected]
This publication is for general information only. It is not legal advice, and legal counsel should be contactedbefore any action is taken which might be influenced by this publication.
