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FinCEN Publishes Proposed Rule to Allow Financial Institutions to Share Suspicious Activity Reports with Foreign Affiliates

International Trade and Investment Alert™ | January 25, 2022

On January 25, 2022 the Financial Crimes Enforcement Network (“FinCEN”) published a notice of proposed rulemaking (“proposed rule”) that would establish a pilot program to allow US financial institutions to share suspicious activity reports (“SARs”) and related information with foreign affiliates, including branches and subsidiaries, in order to combat illicit finance risks. Comments on the proposed rule may be submitted until March 28, 2022, after which FinCEN will issue a final rule implementing the pilot program. FinCEN is creating the pilot program pursuant to the Anti-Money Laundering Act of 2020.

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