In September 2020, just a few weeks before this episode was recorded, there was a leak of thousands of Suspicious Activity Reports (‘SARs’) filed by financial institutions, dubbed the ‘FinCEN leak’. This has caused much discussion about the implications and for some to call for a review of the relevant regulation and compliance systems.
This episode looks at the SAR regime and its requirements, the banks’ obligations, the impact on private clients and what the leak means for the UK’s legal landscape.
Joining Leonora in the discussion are:
- Fountain Court silk Robin Barclay QC, who specialises in civil and criminal fraud, bribery, money laundering and market abuse as well as a wide range of banking and regulatory investigations.
- Partner and Head of Corporate Crime and Investigations at Macfarlanes Neill Blundell, who has been involved in some of the highest profile bribery investigations into BAE, Rolls-Royce and Airbus, as well as benchmark rigging and the investigation into Barclays regarding the 2008 fund raising.
- Managing Director of K2 Intelligence Joanne Taylor who has extensive experience of working for banks in connection with their compliance efforts and is uniquely placed to discuss the FinCEN scandal and what it means for the banks.
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We hope you enjoy the episode.