WASHINGTON—In response to a proposal calling for the establishment of a limited-duration pilot program to give financial institutions the ability to share SARs and SARS-related information with the institution’s foreign branches, NAFCU has written to FinCEN with recommendations.
In the letter, Regulatory Affairs Counsel Aminah Moore offered general support for the program and recommended FinCEN monitor the confidentiality of the shared SAR information and modernize and streamline its SAR reporting requirements. "Information in a SAR, if leaked to parties associated with the SAR, could be used to undermine law enforcement efforts. It is important that foreign branches, subsidiaries, and affiliates respect the confidentiality of SARs," Moore stated.
"NAFCU has always advocated for an enhanced SAR program that allows its members to gain important insights from their filings," Moore continued. "The ability to look at more internal and external information for multiple purposes, including fraud detection, anti-money laundering, and sanctions, and then share that information across both the public and private sector will enable credit unions to carry out the intent of the [Bank Secrecy Act] more effectively."
Additional Requests
In addition, Moore stated that modernization of SAR reporting should include streamlining the e-filing submission system to allow for more auto-fill features. "Changes like this would have long-term impacts in terms of compliance staff spending less time to complete longer SAR forms to communicate the same information if additional auto-fill features were available," concluded Moore.