Regulation

BIS and FinCEN’s joint notice on new Suspicious Activity Report key term

Issue 43.
May 2024

Author
Pablo LeCourSean RyanZach Harris
+ About author

Pablo LeCour is a Principal in Deloitte’s Global Trade Advisory practice in the US.

Sean Ryan is a Principal in Deloitte’s Global Trade Advisory practice in the US (seanryan@deloitte.com).

Zach Harris is a Manager at Global Trade Advisory, Deloitte Tax LLP. www.deloitte.com

In November 2023, the Department of Commerce’s Bureau of Industry and Security (“BIS”) released its third joint notice with the US Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), announcing a new Suspicious Activity Report (“SAR”) key term. SAR key terms are used by financial institutions (“FIs”) to alert FinCEN to suspected cases of fraud or money laundering. The November key term addition followed two joint alerts from FinCEN and BIS, expanding the use of SAR key ...

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