By Aaron Nicodemus2021-01-19T19:25:00+00:00
Congress has ordered a reassessment of the Bank Secrecy Act anti-money laundering (AML) program as part of the National Defense Authorization Act (NDAA) for Fiscal Year 2021 (H.R.6395).
The bill includes a “formal review” of BSA rules regarding the filing of suspicious activity reports (SARs) by financial institutions. Also included are separate AML provisions that pull back the veil on anonymous shell corporations and establish a BSA whistleblower program with financial rewards for tipsters whose information leads to a conviction.
In an ideal world, the U.S. Treasury and the Financial Crimes Enforcement Network (FinCEN) use the information gleaned from SARs to either launch investigations into criminal activity like money laundering or hand off the information contained in the reports to agencies better suited to handle them. For example, FinCEN regularly refers information collected in SARs regarding tax evasion to the Internal Re
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