Guidance on Sharing of Suspicious Activity Reports within Corporate Groups

February 1, 2006

On February 1, 2006, the Washington D.C. office authored an Alert Memorandum entitled “Guidance on Sharing of Suspicious Activity Reports within Corporate Groups.” This five-page memo discusses the interagency guidance the Financial Crimes Enforcement Network (FinCEN) and the federal banking agencies issued on January 20, 2006, on the ability of certain financial institutions to share Suspicious Activity Reports with their head offices, controlling companies and affiliates. The memorandum briefly summarizes some of the key points to the guidance.