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Subject: Bank Secrecy Act/Anti-Money Laundering
Date: May 17, 2007
To: Chief Executive Officers and Compliance Officers of All National Banks, Federal Branches and Agencies, Department and Division Heads, and All Examining Personnel
Description: Notification of Delay in the Implementation of Revised Suspicious Activity Report by Deposit Institutions (SAR-DI)
The attached documents, issued on April 27, 2007, by the Financial Crimes Enforcement Network (FinCEN), announce the delayed implementation of certain revised Suspicious Activity Report (SAR) forms that were scheduled to become effective on June 30, 2007. FinCEN is withdrawing the effective date for the revised SAR forms for depository institutions, casinos and card clubs, insurance companies, and the securities and futures industries. This bulletin also affects the published implementation dates for the Suspicious Activity Report by Depository Institution (SAR-DI) form contained in OCC Bulletin 2007-12, dated March 14, 2007.
FinCEN will establish new effective and mandatory compliance dates for these revised forms in a future notice. This announcement does not affect the BSA filing requirements, and financial institutions should continue filing using the current SAR forms.
For further information, please contact your examiner-in-charge, OCC supervisory office, or the OCC Compliance Policy Department at (202) 874-4428.
Ann F. Jaedicke