[15015]
August 9, 2002
TO: BROKER/DEALER ADVISORY COMMITTEE No. 28-02
MONEY LAUNDERING RULES WORKING GROUP No. 43-02
RE: TREASURY PROPOSES FORM FOR BROKER-DEALER SUSPICIOUS ACTIVITY
REPORTING
As you know, the Department of the Treasury recently adopted a rule that will require
every broker or dealer in securities, including mutual fund principal underwriters, to file
suspicious activity reports (SARs) with Treasury’s Financial Crimes Enforcement Network
(FinCEN).1 The rule applies to transactions occurring after December 30, 2002.
FinCEN has proposed a new form, “Suspicious Activity Report by the Securities and
Futures Industry (SAR-SF)” to be used by broker-dealers to report suspicious activity. A copy
of the release, which includes the proposed Form SAR-SF, is attached.2
The Institute is considering whether to comment on this proposal. Comments must
be filed with FinCEN by October 4th. If there are issues that you would like us to consider
addressing in a comment letter, please contact me at by phone at (202) 371-5430 or by e-mail
at rcg@ici.org or Frances Stadler by phone at (202) 326-5822 or by e-mail at frances@ici.org.
Robert C. Grohowski
Associate Counsel
Attachment (in .pdf format)
1 See Memorandum to Money Laundering Rules Working Group No. 33-02 and Broker-Dealer Advisory Committee
No. 16-02, dated July 2, 2002.
2 Financial Crimes Enforcement Network; Proposed Collection; Comment Request; Suspicious Activity Report by the
Securities and Futures Industry, 67 Fed. Reg. 50751 (August 5, 2002).