bank secrecy act / anti-money laundering (bsa/aml) compliance

INTERNAL CONTROLS - REPORTINGSUSPICIOUS ACTIVITY REPORTS Must retain copies of SARs and supportingdocumentation for 5 years from the date of thereport. NO disclosure to anyone involved in thetransaction that a SAR has been filed. May ONLY inform FinCEN, law enforcement orfederal banking agencies.SUSPICIOUS ACTIVITY REPORTSSAFE HARBOR Credit union directors, officers, employees and agentsthat reports a suspicious transaction to theappropriate authorities are granted a safe harbor fromany civil liability under any law or regulation,regardless of whether such reports are filed pursuantto the SAR instructions. This safe harbor applies to SARs filed within the requiredreporting thresholds as well as those filed voluntarily on anyactivity below the threshold.22