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Financial Institutions › Suspicious Activity Reports (SARs) › Safe Harbors

Ballard Spahr LLP

32 Attorneys General call for enactment of marijuana banking legislation

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Thirty-two attorneys general representing states, territories and Washington, D.C. are asking Congress to pass legislation to provide financial institutions a safe harbor if they provide services to marijuana-related...more

McGuireWoods LLP

FinCEN Director Blanco Comments on Section 314(b)’s New Guidance

McGuireWoods LLP on

On December 10, 2020, FinCEN Director Kenneth Blanco delivered prepared remarks at the ABA’s annual Financial Crimes Enforcement Conference. At the outset, Director Blanco addressed the importance of U.S. national security...more

Ballard Spahr LLP

Proposed AML Reforms Aim to Enhance and Modernize AML/CFT Enforcement

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Second Post in a Two-Post Series on the ILLICIT CASH Act - A discussion draft of legislation recently introduced in the Senate, the Improving Laundering Laws and Increasing Comprehensive Information Tracking of Criminal...more

Seyfarth Shaw LLP

Will Banks be Able to Play it SAFE with Marijuana Related Businesses?

Seyfarth Shaw LLP on

Marijuana is estimated to be a $10 billion industry and rapidly growing. Almost all of it is conducted in cash. Although legal in thirty three states plus Washington, D.C., Puerto Rico and Guam, marijuana remains illegal at...more

Ballard Spahr LLP

First Circuit Confirms Broad Civil Immunity for Filing a SAR

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As we previously blogged, the District of Massachusetts held in AER Advisors Inc. v. Fidelity Brokerage Services, LLC, that the safe harbor provision of the Bank Secrecy Act (BSA) provides unqualified protection to financial...more

Ballard Spahr LLP

Just How Safe Is the SAR Safe Harbor Provision?

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Congress enacted the safe harbor provision of the Bank Secrecy Act (BSA), codified at 31 U.S.C. §5318(g)(3)(A), to shield financial institutions, their officers and employees from civil liability for reporting known or...more

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