Regulatory Alerts2004-12-14
Added
Interpretation of Suspicious Activity Reporting Requirements to Permit the Unitary Filing of Suspicious Activity and Blocking Reports
FinCEN deems the filing of a blocking report with OFAC to satisfy the requirement to file a suspicious activity report for transactions involving Specially Designated Global Terrorists, Specially Designated Terrorists, Foreign Terrorist Organizations, Specially Designated Narcotics Trafficker Kingpins, and Specially Designated Narcotics Traffickers. This unitary filing applies only to the fact of the OFAC match and does not relieve financial institutions of the obligation to file separate suspicious activity reports for information not included in the blocking report or for suspicious activity independently identified beyond the match. The interpretation explicitly excludes blocking reports related to transactions involving persons owned by or nationals of countries subject to OFAC-administered sanctions programs.