2019-12-04 | PDF Only

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Increased Prevalence of 314(b) References in SAR Narratives

The number of Suspicious Activity Reports (SARs) referencing the 314(b) Program in the narrative increased by 44 percent in 2016 compared to 2015, while the number of financial institutions filing such SARs rose by 37 percent. Terrorist financing SARs referencing 314(b) grew from 25 in 2012 to 96 in 2016, indicating increased information sharing among financial institutions. Depository institutions and broker-dealers constitute the majority of participants, with casinos and insurance companies showing dramatic increases in 2016. Most reports involve money laundering, specifically concerning the source of funds, as institutions seek clarity from other participants.

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Financial Crimes Enforcement Network

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