At Jacko Law Group, we provide strategic, actionable guidance to help financial institutions and investment firms meet their regulatory obligations with confidence. Our comprehensive AML compliance services are a cornerstone of our broader compliance offerings, designed to protect your firm, your clients, and your reputation.
Navigating Suspicious Activity Reports (SARs) with Confidence
Filing a Suspicious Activity Report (SAR) is not just a regulatory obligation, it’s a legal judgment call that can have significant implications. Knowing when to file, what to include, and how to properly document suspicious activity requires more than training, it requires experienced legal counsel.
SEC Registered Investment advisers, Exempt Reporting Advisers, Broker-Dealers and others in the financial industry are subject to a range of AML requirements, which are designed to detect and prevent money laundering and other fraudulent financial activity, including the financing of terrorist acts.
It is crucial for businesses to recognize that AML compliance is a priority. They must implement and adopt protocols and practices tailored to their business’ objectives and risk profile.
At Jacko Law Group, our professionals bring unique insight as former investment advisers, broker-dealers, and seasoned compliance attorneys. We understand firsthand the operational pressures and regulatory expectations firms face. Our team provides strategic guidance across AML program design, SAR obligations, and regulatory readiness, ensuring your compliance program is both effective and meets AML compliance requirements.
AML requirements are established under several laws including:
Bank Secrecy Act (BSA) – 1970
The BSA is the foundation of AML regulations in the country and sets requirements for recordkeeping and reporting of certain transactions and suspicious activity such as Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) to FinCEN.
USA PATRIOT Act – 2001
The PATRIOT ACT, enacted in response to 9/11, expands requirements of the BSA for certain financial institutions to include Customer Identification Programs (CIP) and Enhanced Due Diligence (EDD), and encourages information sharing between financial institutions, and with federal agencies.
Anti-Money Laundering Act (AML) – 2020
The Anti-Money Laundering Act of 2020 (AMLA) introduced the most sweeping AML/CFT reforms in decades. The AML was enacted to enhance financial transparency, strengthen enforcement against illegal finance, and modernize risk-based AML compliance programs by requiring beneficial ownership disclosure, promoting whistleblower protections, and aligning U.S. regulations with global anti-money laundering standards.
2024 AML Rulemaking Updates
In 2024, FinCEN further expanded the AML rule to include:
Corporate Transparency Act (CTA) – Effective 2024
A key provision of the AML Rule, the CTA requires certain companies to report beneficial ownership information to FinCEN. This improves transparency and helps law enforcement track illicit actors hiding behind shell companies.
FinCEN’s AML Rule on Investment Advisers – Effective January 1, 2025
In a significant expansion of AML obligations, FinCEN finalized a rule in 2024 requiring SEC-registered investment advisers (RIAs) and exempt reporting advisers (ERAs) to establish AML programs, conduct customer due diligence (CDD), and file SARs. Compliance is required by January 1, 2026.
These evolving laws reflect the government’s increasing focus on risk-based AML compliance frameworks that are tailored, proactive, and continuously monitored.
Jacko Law Group is one of the nation’s leading Business and Securities law firms. Founded and run by leading Regulatory and Compliance attorney Michelle L. Jacko, Esq., the firm has almost two decades of experience helping businesses with their legal needs, from complex disputes and compliance counsel to effective securities litigation.
