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Home > FAQs > Compliance > Anti-Money Laundering ("AML") Programs > May I share a SAR with an affiliate?

May I share a SAR with an affiliate?

Yes, under certain circumstances. A firm may share a SAR with a parent entity, both domestic and foreign, for the purpose of the parent entity fulfilling its oblication to review for compliance by its subsidiaries with respect to suspicious activity reporting. The firm, however, must have a written confidentiality agreement or other arrangement with the parent specifying that the parent entity must protect the confidentiality of the SAR through appropriate internal controls. Firms may also share a SAR with an affiliate, provided the affiliate is subject to a SAR regulation issued by FinCEN or other regulatory agency.

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