Open up: US set to pilot cross-border SAR sharing

Michael D. Mann (+1 212 839 5837, mdmann@sidley.com & Brian P. Morrissey (+1 202 736 8407, bmorriss@sidley.com) are partners at Sidley Austin LLP and members of the firm’s White Collar: Government Litigation and Investigations practice group.

Serious financial crime is borderless but firms regulated for anti-money laundering have long found it illegal, or highly problematic at the least, to share details of suspicious activity reports on clients outside the jurisdiction in which they were filed. The United States is now seeking to regain some initiative against illicit finance by allowing SARs to be shared internationally intra-group for the first time. Michael D. Mann & Brian P. Morrissey of Sidley Austin LLP examine the fine print in FinCEN’s proposal.