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Alerts
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Proposed Rules and Interpretative Guidance on the Confidentiality of Suspicious Activity Reports: Comment Period Expires on June 8, 2009
April 22, 2009
On March 3, 2009, the Financial Crimes Enforcement Network (“FinCEN”) announced a proposed rule clarifying the scope of the statutory prohibition against the disclosure of a Suspicious Activity Report (“SAR”), and issued two sets of proposed related interpretive guidance that permit the sharing of SARs with certain U.S. affiliates of depository institutions, as well as broker-dealers in securities (“BDs”), mutual funds, futures commission merchants (“FCMs”), and introducing brokers in commodities (“IB-Cs”).
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