Beyond the Bank: The SAR Framework, Information Sharing and the New World of Corporate AML Compliance

January 2026

Abstract

This paper examines Suspicious Activity Reporting (SAR) frameworks and information-sharing mechanisms under Sections 314(a) and 314(b) of the USA PATRIOT Act as critical tools for detecting and mitigating financial crime risk within corporate compliance programs. As emerging technologies such as artificial intelligence and cryptocurrency transform the threat landscape, organizations face unprecedented compliance pressures requiring specialized programs across industries. The paper outlines best practices for documenting and investigating potential misconduct, emphasizing objective fact-gathering, evidence preservation, and appropriate escalation to maintain regulatory defensibility. It distinguishes government-initiated inquiries under Section 314(a) from voluntary institution-to-institution collaboration under Section 314(b), highlighting confidentiality obligations and operational safeguards. While traditionally associated with financial institutions, SAR requirements have expanded to cryptocurrency exchanges and non-financial businesses, increasingly intersecting with corporate environments through vendor payments, expense programs, and digital asset transactions. Regulatory shifts now mandate modernized transaction monitoring, AI-powered detection, and risk-based frameworks across "gatekeeper" industries from accountancy to legal services. Effective implementation requires disciplined documentation, privilege awareness, and technology-enhanced due diligence. Organizations that operationalize these controls demonstrate good-faith compliance, strengthen governance frameworks, and reduce regulatory exposure while supporting broader anti-money laundering and counter-terrorism objectives.

Authors

Jillian Thompson

Senior Compliance Associate, Moore Capital Management, LP, USA

Jillian Thompson is a Senior Compliance Associate at Moore Capital Management, LP, a New York-based private investment management firm, where she supports the execution of the firm's corporate compliance and regulatory framework, including market risk and trade surveillance, derivatives monitoring, MNPI controls, Code of Ethics oversight, and political contribution compliance. With over seven years of experience navigating the complex regulatory landscape governing investment advisers, including SEC, FCA, CFTC, and NFA requirements, Jillian has developed a deep appreciation for the unique compliance challenges facing investment managers. Before entering financial services, Jillian received her bachelor’s degree in sociology from Hunter College and worked with New York City non-profits, an experience that continues to shape her commitment to ethical business practices and community-centered leadership. She is a strong advocate for leveraging emerging technology to enhance compliance operations and firmly believes that a robust compliance program is not just a regulatory obligation but a strategic value-add that strengthens business integrity and investor confidence.

Lincoln Gleeton

Master of Studies in Law (MSL) in Corporate Compliance , Fordham University School of Law, USA

Lincoln Gleeton is a corporate compliance professional currently pursuing a Master of Studies in Law (MSL) in Corporate Compliance at Fordham University School of Law. His graduate studies are shaping the foundation of his career as a strategic compliance leader, with focused coursework in corporate governance, anti-corruption enforcement, anti-money laundering frameworks, regulatory investigations, and enterprise risk management. Through this program, he is developing a sophisticated understanding of how legal theory, regulatory expectations, and business operations intersect to form resilient compliance infrastructures. His academic work centers on designing structured, data-driven compliance programs that integrate risk assessment, internal controls, monitoring, and ethical governance principles. He is particularly interested in building compliance frameworks that move beyond reactive remediation toward proactive risk mitigation, measurable performance metrics, and board-level accountability. His goal is to serve in senior compliance leadership roles where he can align regulatory strategy with organizational growth and operational integrity. Professionally, he brings experience from highly regulated industries, including aviation and mortgage servicing. He has held compliance and risk-related roles at JetBlue Airways, NewRez LLC, and Shellpoint Mortgage Servicing. At Shellpoint, he managed multi-jurisdictional foreclosure litigation portfolios, ensuring adherence to state statutes, investor requirements, and regulatory standards while strengthening documentation controls and mitigating operational risk. At NewRez, he conducted quality control reviews of servicing files to assess compliance with federal and state regulations, identify control deficiencies, and support remediation initiatives. During his tenure at JetBlue, he contributed to enterprise ethics and compliance initiatives, including third-party due diligence, internal review processes, and program enhancements aligned with evolving regulatory expectations. Together, his professional experience and legal education position him to contribute meaningfully to organizations operating in complex regulatory environments. His long-term objective is to lead enterprise compliance programs that are strategic, measurable, and embedded into corporate culture, ultimately strengthening both ethical governance and sustainable business performance.

Companies

Moore Capital Management, LP

N/A

Fordham University School of Law

Fordham’s M.S.L. is a graduate program for professionals seeking advanced legal training without pursuing a J.D. The Corporate Compliance specialization focuses on regulatory frameworks, risk assessment, anti-money laundering, anti-corruption, securities regulation, and the design of effective compliance programs. The curriculum emphasizes practical application, governance strategy, and leadership development, culminating in a capstone project that integrates legal theory with real-world compliance practice.