Article: Cyber SAR – Does the Securities and Futures Industry Get It?

In October, 2016, Department of Treasury’s Financial Crimes Enforcement Network (FINCEN) published an advisory (the “October Advisory”) directing financial institutions to start reporting “cyber-enabled crime and cyber-events” through SARs, making the reporting of those connections mandatory.  The significance of the “cyber-enabled crime” restatement for firms is its guidance on what cyber-crime related data must be included in the SAR: the broadening of the reporting requirement to include “cyber-events.”