In an article published in The Tennessee Banker, Bass, Berry & Sims attorney John Speer provided insight on the Financial Crimes Enforcement Network's (FinCEN) recent advisory regarding Suspicious Activity Report (SAR) filing for financial institutions related to cyber events and cyber-enabled crime. The advisory is the most recent FinCEN guidance reflecting its increased emphasis on SAR reporting of suspicious cyber threats and the cyber events that could trigger an SAR filing. This advisory also specifies the cyber information that should be included in SAR filings involving any reportable suspicious activity. In the article, John suggests that public and private companies should pay greater attention to the detection of and communication about cyber attacks, whether successful or not, in order to comply with existing law and regulations.
The full article, "FinCEN SAR Filing Advisory Expands Reporting of Cyber Threats," was published in the January/February 2017 issue of The Tennessee Banker and is available online. The publication is a bi-monthly magazine issued by the Tennessee Bankers Association.