Regulatory Alerts2004-12-23
Added · Updated
Guidance (Interpretive Release No. 2004-02) - Unitary Filing of Suspicious Activity and Blocking Reports (Final Rule)
FinCEN clarifies that filing a blocking report with OFAC for transactions involving designated terrorists or narcotics traffickers satisfies the requirement to file a suspicious activity report for the fact of the match. This unitary filing applies to Specially Designated Global Terrorists, Specially Designated Terrorists, Foreign Terrorist Organizations, Specially Designated Narcotics Trafficker Kingpins, and Specially Designated Narcotics Traffickers. Financial institutions must still file separate suspicious activity reports if they possess information not included in the blocking report or if the transaction is independently suspicious beyond the OFAC match. This interpretation does not apply to blocking reports involving persons owned by or nationals of countries subject to OFAC-administered sanctions programs.