The Safe Harbor Provision under the BSA shields financial institutions, their officers and employees from civil liability for filing Suspicious Activity Reports (SARs).  It provides immunity to “any financial institution that makes a voluntary disclosure of any possible violation of law or regulation to a government agency.”1  While the language suggests absolute immunity, some courts have read a good faith requirement into the statute.


1 31 USC § 5318(g)(3)(A); see 31 CFR § 1020.320(f). 


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