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Bank secrecy

Reporting duties under the Bank Secrecy Act.

FIN-06 · 01

Suspicious Activity Reports: Filing Standards and the Confidentiality Rule

8 MIN · FIN

A SAR is the one filing a customer must never learn about. This brief sets out what triggers the obligation, how the 30-day clock runs, who may lawfully be told, and what the statutory safe harbour actually protects.

A SAR is due within 30 calendar days of initial detection of facts that may form a basis for filing, extendable to 60 if no suspect is identified.
Federal law makes both the report and its very existence confidential; a bank may not tell the customer, and disclosure carries its own penalties.
The statute grants a safe harbour from liability to the filer and its people for reporting a possible violation, whether or not the suspicion proves correct.

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FIN-07 · 02

Custodial and FBO Account Structures: Whose Money Is It

8 MIN · FIN

An FBO account holds one balance at a bank and many claims outside it. This brief separates legal ownership from operational control, and sets out the titling, records, and disclosure conditions the structure depends on.

An FBO account is a single deposit at a bank held by an intermediary for identified end users, whose individual claims exist only in the intermediary's ledger.
Pass-through insurance conditions include custodial titling, records identifying the true owners and their interests, and a genuine disclosed agency relationship.
The label 'FBO' on an account title creates nothing by itself; the underlying agreements and state law determine whether a trust or agency actually exists.

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