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Subject: Bank Secrecy Act/ Anti-Money Laundering
Date: August 30, 2007
To: Chief Executive Officers, BSA Officers, and Compliance Officers of All National Banks; Federal Branches and Agencies; Technology Service Providers; Department and Division Heads; and All Examining Personnel
Description: Suspicious Activity Report (SAR) Supporting Documentation
On June 13, 2007, the Financial Crimes Enforcement Network (FinCEN) issued new guidance addressing SAR Supporting Documentation (see attached). The guidance clarifies three issues: BSA regulatory requirements as they relate to supporting documentation, what constitutes "supporting documentation," and when legal process is required for supporting documentation disclosure.
Ann F. Jaedicke