To assist law enforcement in investigating and prosecuting possible criminal activity involving Payment Processors, the Financial Crime Enforcement Network (FinCEN) requires that financial institutions file Suspicious Activity Reports (SAR) if they know of or suspect illegal activity. This process furthers the Department of the Treasury’s broader efforts to protect the U.S. financial system from money laundering and terrorist financing. By implementing effective and appropriate controls over processors and their merchant clients, a bank can identify processors that conduct fraudulent transactions and fulfil SAR obligations.


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