Suspicious activity reporting
Suspicious activity reporting obligations in the Technology, AI and Competition sector are tightening, with the Financial Crimes Enforcement Network and the U.S. Department of Justice Antitrust Division both signaling heightened scrutiny of how tech platforms flag and escalate potential violations internally. FinCEN's 2023 guidance on digital asset intermediaries extended SAR filing requirements to a broader class of technology firms than many compliance teams had previously mapped against their obligations. The question for most legal and risk functions right now is not whether SAR frameworks apply, but which business lines trigger them.
Watch
- FinCEN's digital asset SAR guidance: which tech intermediaries must file
- DOJ Antitrust Division voluntary self-disclosure policy and its interaction with SAR timelines
- BSA obligations for AI-enabled payment and lending platforms now under active enforcement review
- EU Anti-Money Laundering Authority's 2025 jurisdiction expansion into crypto-asset service providers
- State-level money transmission license conditions that impose parallel SAR duties on fintech firms
Recent material activity in Technology, AI & Competition
-
NIST releases updated AI Risk Management Framework companion guide for critical infrastructure
NIST published AI RMF 1.1 companion guidance specifically addressing AI deployment in critical infrastructure sectors including energy, financial services, and healthcare. The guide introduces mandatory risk assessment c…
Read a full sample brief →