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Pilot Program on Sharing of Suspicious Activity Reports and Related Information With Foreign Branches, Subsidiaries, and Affiliates

Detected July 30, 2026 · in Money Services & Money Transmitters

FinCEN proposes a limited-duration pilot program allowing money services businesses to share suspicious activity reports (SARs) with foreign branches, subsidiaries, and affiliates for AML purposes. Public comments are due by March 28, 2022.

Aforeworn detected this change in the Money Services & Money Transmitters space on July 30, 2026 and published this briefing so affected operators are forewarned rather than caught off guard. It is rated Low urgency. Money services businesses (MSBs), including payment processors, crypto/virtual-currency firms, remittance providers, and fintech wallets with foreign branches, subsidiaries, or affiliates. should confirm how it applies to their specific situation before acting. There is a time constraint attached: March 28, 2022 (comment deadline).. Acting after that point can mean penalties, a lapsed licence, or lost eligibility — exactly the kind of surprise Aforeworn exists to prevent. Aforeworn monitors Money Services & Money Transmitters continuously and turns every detected change into a plain-English briefing like this one, so you always know first. Forewarned is forearmed.

What changed

Proposed rule would create a pilot program permitting SAR sharing with foreign entities under certain conditions, subject to public comment.

Who it affects

Money services businesses (MSBs), including payment processors, crypto/virtual-currency firms, remittance providers, and fintech wallets with foreign branches, subsidiaries, or affiliates.

What you must do

Review the proposed rule and submit public comments by March 28, 2022, if desired.

Deadline

March 28, 2022 (comment deadline).

Source: https://www.federalregister.gov/documents/2022/01/25/2022-01331/pilot-program-on-sharing-of-suspicious-activity-reports-and-related-information-with-foreign

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