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Our Take Blog

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Our Take Blog
BDs Must Make SAR Information Available to FINRA

BDs Must Make SAR Information Available to FINRA

The SEC’s Office of Compliance Inspections and Examinations has issued an open letter to all FINRA member broker-dealers instructing them to make all Suspicious Activity Reports and related documentation available to FINRA during examinations.  The letter implements changes to the Bank Secrecy Act.  FINRA, in turn, must keep such information confidential.  Required information includes Suspicious Activity Reports, supporting documentation, and “any information that would reveal the existence of a SAR or any decision to not file a SAR.”
OUR TAKE: The change delegates to FINRA supervision of broker-dealer compliance with the Bank Secrecy Act.
http://sec.gov/about/offices/ocie/brokerdealerletter.htm
http://sec.gov/about/offices/ocie/finraletter.htm
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