The High Points: SARs and the Three Tiered Framework for MRBs
October 1, 2020
by Allison E. Raley
As green states continue to grow, intentional or unintentional exposure to Marijuana Related Business (“MRB”) customers for financial institutions and broker-dealers is an inevitability. Whether your business has decided to actively shoulder the risk of allowing MRB customers in pursuit of the…
Accuracy Counts: Filing Complete and Accurate SARs and Program Specific Red Flags Related to Covid-19 Criminal or Fraudulent Activity
On September 29, 2020, at the 19th Annual AML & Anti-Financial Crime Conference, Financial Crimes Enforcement Network (“FinCEN”) Director Kenneth Blanco reported over 91,000 suspicious activity reports (“SARs”) have been filed related to Covid-19 criminal and fraudulent activity. These 91,000…