Gain a better understanding of suspicious activity reporting and the bounds of SAR confidentiality.
Many persons involved in lending arrangements may not fully understand whether the arrangement is subject to anti-money laundering (AML) compliance requirements, including the need to file suspicious activity reports (SARs) with the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN), what is required to be reported on SARs, how they are filed with FinCEN, and why they need to be kept confidential. This presentation will help those involved in lending arrangements understand the federal anti-money laundering (AML) compliance requirements applicable to their business, with a particular focus on suspicious activity reporting and the bounds of SAR confidentiality.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Agenda
The Bank Secrecy Act (BSA)
- Overview of the BSA
- Anti-Money Laundering (AML) Program Requirement
Applicable AML Laws to Lending Arrangements
- What Is a Loan or Finance Company?
- What Is a Residential Mortgage Lender or Originator?
The Suspicious Activity Report (SAR) Filing Requirement
- History of the SAR Filing Requirement
- When Are SAR Filings Required?
- How Quickly Do SARs Need to Be Filed?
FinCEN Form 111
- How to File SARs With FinCEN
- What Information Is Contained on the SAR Form?
- How to Write Effective SAR Narratives
SAR Confidentiality
- Disclosing to FinCEN and Law Enforcement
- Disclosing Within the Corporate Organizational Structure
- SAR Filing Requirement: Penalties
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Credits
OnDemand Course
This course was last revised on November 18, 2022.
Call 1-866-352-9540 for further credit information.
- ACFE 1.5
- This program is applicable for 1.5 compliance or recertification CPE(s) through the Association of Certified Fraud Examiners (ACFE). Please visit the ACFE website for further clarification: https://www.acfe.com/cfe-credential/continuing-professional-education-cpe-requirements.
- AK CLE 1.25
- Alaska attorneys may receive 1.25 hours of continuing legal education for completing this program. Please contact the Alaska Bar Association or go to www.alaskabar.org for details regarding reciprocity with other states.
- AL CLE 1.2
- This course or a portion thereof has been approved by the Alabama State Mandatory Continuing Legal Education Commission for a maximum of 1.2 hours credit.
- AR CLE 1.25
- This course has been approved for 1.25 hours of CLE by the Arkansas CLE Board.
- Arizona CLE 1.25
- The Arizona State Bar does not pre-approve or pre-certify MCLE programs. However, records of this program and attendance will be maintained by Lorman Education Services for auditing purposes. This activity may qualify for up to 1.25 hours toward your annual CLE requirement for the State Bar of Arizona.
- CA MCLE 1.25
- Lorman Education Services is a State Bar of California approved MCLE sponsor and this course qualifies for 1.25 CLE hours of participatory credit.
- CT CLE 1.0
- Neither the Connecticut Judicial Branch nor the Commission on Minimum Continuing Legal Education approve or accredit CLE providers or activities. This course has been approved for CLE credit in jurisdictions aside from CT and therefore it automatically meets the content and delivery requirements in Connecticut. Credit is based on a 60 minute credit hour and shall be awarded as follows: 1.0 CLE credit(s).
- GA CLE 1.0
- This program has been approved by the Georgia Commission on Continuing Lawyer Competency for 1.0 CLE hours.
- HI CLE 1.0
- This program was approved by the Hawaii State Board of Continuing Legal Education for 1.0 CLE credit hours.
- MO CLE 1.5
- This course qualifies for self-study CLE credit in Missouri.
- ND CLE 1.25
- North Dakota CLE policy does not allow for pre-approval of any self-study courses. This course may qualify for up to 1.25 hours of CLE credit.
- NH MCLE 1.2
- NH MCLE does not approve or accredit CLE activities for the NH Minimum CLE requirement. Lorman Education Services believes this Ondemand course meets the requirement of NH Supreme Court Rule 53 and may qualify for CLE credit(s). Program Length: 72 Minutes.
- NM CLE 1.2
- This program has been approved by the New Mexico Minimum Continuing Legal Education Board for 1.2 hours of credit.
- NV CLE 1.0
- This program has been approved by the Nevada Board of Continuing Legal Education for 1.0 CLE hours.
- RI CLE 1.0
- This program has been approved by the Rhode Island Mandatory Continuing Legal Education Commission for 1.0 hours of CLE credit.
- VT CLE 1.0
- This self-study program has been approved by the Mandatory Continuing Legal Education Board of Vermont for 1.0 hour(s) of CLE credit. Please note: Attorneys may only claim 12 credits per compliance period in this format. This course is considered "Non-Moderated Programming without Interactivity".
To earn each credit Lorman offers through the OnDemand learning platform, you need to watch 100% of the program. Also, for certain credits you will need to fulfill additional requirements which will be displayed on the "credits" tab when viewing the course.
This program does NOT qualify, nor meet the National Standard for NASBA accreditation.
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
Faculty
Melissa G. R. Goldstein
Schulte Roth & Zabel
- Partner, Schulte, Roth & Zabel LLP
- Advises banks, broker-dealers, investment advisers, funds, insurance companies, and money services businesses, including those involved in global e-commerce and virtual currency, on the anti-money laundering and sanctions regulations, rules, and related issues governing their investment and business activities
- Expertise with issues arising out of the USA PATRIOT Act, as amended by the Bank Secrecy Act
- Frequent speaker on anti-money laundering-related issues
- Previous attorney-advisor with the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), where she assisted in the development of anti-money laundering regulations and guidance and served as counsel on enforcement actions involving issues such as failure to implement and maintain an adequate anti-money laundering compliance program, failure to register as a money services business, and failure to maintain the confidentiality of suspicious activity reports
- J.D. degree, Fordham University School of Law; B.S. degree, with honors, Cornell University
- Can be contacted at 202-729-7471 or [email protected]
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Why Lorman?
Over 37 years and 1.4 million customers worth of experience providing continuing education. Our passion is providing you world-class training to help you succeed in business and as a professional.
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