Most people would naturally assume that board reporting was part of the BSA regulation.
However, if you think about it, why on earth would FinCEN want SAR filings reported to the Board? As one of the ABA's more crispy comment letters pointed out, reporting SARs to the board is "counterintuitive" and acts as an upward delegation of responsibility after the fact.
Clearly, that's the regulatory agencies' forte.
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In this world you must be oh so smart or oh so pleasant. Well, for years I was smart. I recommend pleasant.