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Alerts
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Guidance on the Scope of Permissible Information Sharing Covered by the Safe Harbor of Section 314(b) of the USA PATRIOT Act
June 23, 2009
On June 16, 2009, the Financial Crimes Enforcement Network (“FinCEN”) issued interpretative guidance to clarify the scope of permissible information sharing covered by the safe harbor protection of Section 314(b) of the USA PATRIOT Act (the “Guidance”). The Guidance clarified that a financial institution that complies with the requirements of Section 314(b) may share information relating to transactions that a financial institution suspects may involve the proceeds of one or more specified unlawful activities (“SUAs”), as defined under the federal money laundering statutes and remain within the protection of the Section 314(b) safe harbor.
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