by John P. Cunningham and Trevor N. McFadden, Compliance & Investigations, Washington, D.C.
Although the Financial Crimes Enforcement Network (“FinCEN”) is often perceived as the aggregator of Suspicious Activity Reports (“SARs”) and other federally-mandated financial forms and reports, its actual activities extend well beyond the information-gathering role suggested by its designation as a “Network.” FinCEN, in fact, makes proactive use of its regulatory and enforcement powers. Indeed, it was involved in 19 of the 20 largest anti-money laundering (“AML”) settlements with banks in the last decade.
