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If a bank officer discloses to the bank attorney that the bank officer plans to file a SAR, is that is considered an “unauthorized disclosure”? – IBA Compliance Connection

IBA Compliance Connection

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If a bank officer discloses to the bank attorney that the bank officer plans to file a SAR, is that is considered an “unauthorized disclosure”?

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After discussing with FinCEN’s legal department, we do not believe that the disclosure of a suspicious activity report (SAR) to the bank’s legal counsel would be an unauthorized disclosure. As an agent of the bank, the attorney can review the SAR without violating the SAR confidentiality rule. See 31 CFR 1020.320. In fact, FinCEN has suggested that banks might consult with legal counsel before filing SARs. SAR Activity Review, November 2003 (p. 54).