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Financial Services Law Insights and Observations

OCC issues final rule on authority for SAR requirements

Bank Regulatory Federal Issues Financial Crimes OCC Agency Rule-Making & Guidance SARs Of Interest to Non-US Persons Bank Compliance Bank Secrecy Act Anti-Money Laundering

On April 14, the OCC issued a bulletin reminding regulated banks of a final rule amending the agency’s suspicious activity report (SAR) regulations. The final rule takes effect May 1 (covered by InfoBytes here). Generally, the final rule clarifies the processes by which the OCC may issue exemptions from the requirements of the SAR regulations “based on a request … [for an exemption] that meets the criteria specified in the final rule.” The bulletin notes, however, that the final rule does not itself create any exemptions from the SAR regulations.