Drivers' Licenses are of particular concern to financial institutions as they follow the dictates of their Customer Identification Programs when new customers establish their banking relationships.
The 1st Circuit Court of Appeals has held that a bank who filed a CRF, the predecessor of a SAR, was entitled to absolute civil immunity under the safe harbor provisions of the Annunzio-Wiley Anti-Money Laundering Act 31 U.S.C. 5318(g)(3).
The 2nd Circuit Court of Appeals interpreted the "safe harbor" protection from liability for institutions filing an SAR and held there exists a broad and unambiguous provision for immunity from any law (except the federal Constitution) for any sta
The 11th Circuit Court of Appeals in 1997 held that verbal instructions from government authorities, by themselves, are not enough to form a good faith basis to suspect a violation of a law or statute.