Regulatory Alerts2016-12-01
Added
Supplemental Information Regarding the Final Rule Imposing the Fifth Special Measure Against FBME Bank, Ltd.
FinCEN provides further explanation addressing comments from FBME Bank, Ltd. regarding the agency's use of aggregate Suspicious Activity Report (SAR) data in the final rule imposing a prohibition on covered financial institutions from opening or maintaining correspondent accounts for the bank. The agency clarifies that SARs served as qualitative evidence affirming concerns about shell company activity and money laundering, rather than being the sole basis for the determination. FinCEN rejects arguments that SARs are categorically invalid due to over-inclusion, that absolute transaction volumes should be viewed as percentages of total activity, or that comparisons with other banks are required to establish risk.
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