THE SHAPE OF THINGS TO COME: SARS WILL BE REQUIRED OF AN EXPANDED CLASS OF MSBs

A senior American government official stated this week that Suspicious Activity Reports, more commonly known as SARs, would soon be required of an expanded group of money service businesses. The types of MSBs that are expected to be named are believed to include;

(1) Credit card companies.
(2) Investment advisers, including hedge funds.
(3) Check cashing firms.

Inasmuch as the creation of an effective compliance program, that includes training in the recognition of possible suspicious activities, and the prompt filing of SARs, takes some time to build, it should should now be a priority in the above industries, and elsewhere in the MSB world, lest they be forced to construct a compliance program on a deadline.