On January 25, 2022, the Financial Crimes Enforcement Network (FinCEN) published a notice of proposed rulemaking (NPRM) inviting comment on its proposed establishment of a limited-duration pilot program to permit a financial institution with a suspicious activity report (SAR) reporting obligation to share SARs and information related to SARs with the institution’s foreign branches, subsidiaries, and affiliates for the purpose of combating illicit finance risk.
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