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Trends in Fund Companies’ AML Programs and SAR Filings


Anti-money laundering compliance officers (AMLCOs) often observe situations where their clients or partners may struggle with deciding whether to report suspicious activity in accounts where no suspect can be identified. Based on recent regulatory filings, there appears to be an increase in suspicious activity detection and reporting by financial institutions (FIs), even in instances where the suspicious activity detected falls short of reporting requirements.

Such voluntary reporting provides law enforcement, regulators and the industry more robust information that may be leveraged to enhance anti-money laundering (AML) and financial crime prevention. This article will explore the reporting requirements imposed on investment companies and discuss what conclusions can be reached about trends in reporting suspicious activity.

Foreside’s Nancy Tyminski, Fund Chief Compliance Officer, broke down information obtained from service providers and other financial industry representatives —specifically the TA AMLCOs. Learn how they have seen an increase in suspicious activity over the past two years, as further evidenced by FinCEN SAR data. Read her full report HERE .