WASHINGTON-Interpretive guidance issued last week by Financial Crimes Enforcement Network Director William Fox eliminates the need for duplicative filing with FinCEN and the Office of Foreign Asset Control. Previously, financial institutions had to file Suspicious Activity Reports with FinCEN when they had already filed documentation with OFAC on entities listed as blocked. Under the new interpretation, OFAC will provide the necessary information to FinCEN so a second filing is not necessary. However, Fox reminded in the guidance, “This interpretation does not affect a financial institution’s obligation to identify and report suspicious activity beyond the fact of the OFAC match. To the extent that the financial institution is in possession of information not included on the blocking report filed with OFAC, a separate suspicious activity report should be filed with FinCEN including that information.” It also said the new guidance does not mean financial institutions will not have to file when the activity is considered “independently suspicious” from the OFAC listing, among a few other noted situations.

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