On December 15, 2011, the Financial Crimes Enforcement Network (“FinCEN”) assessed a $25,000 civil money penalty against a bank employee for unlawfully revealing the existence of a Suspicious Activity Report (“SAR”) to the subject of the SAR (“CMP”). FinCEN determined that the bank employee violated the Bank Secrecy Act (BSA) and its implementing regulations by willfully disclosing the existence of a SAR to a person involved in the reported transaction.
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