SAR Confidentiality

When a financial institution investigates suspected fraud, that review may result in a Suspicious Activity Report (SAR), a confidential filing used to report potentially suspicious activity to federal regulators. But when related documents are later requested in litigation, knowing where confidentiality protections apply can help prevent unnecessary disclosure of sensitive information. Polsinelli shareholder and former OCC enforcement lawyer Travis Nelson examines where SAR confidentiality begins and ends, and what financial institutions should consider before producing investigative materials.

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