Former DOJ Official Eun Young Choi Explains New National Security Pressures on SAR Compliance in GIR

Eun Young Choi, Arnold & Porter White Collar Defense & Investigations partner and former Deputy Assistant Attorney General in the National Security Division at the U.S. Department of Justice, was quoted in the Global Investigations Review article, “Improper SARs put banks at risk of terrorism charges,” following her participation in the “GIR Live: National Security Risks and Compliance 2025” panel. The article examined how new U.S. designations of Latin American drug cartels as foreign terrorist organizations could significantly heighten enforcement risks for financial institutions that fail to properly file suspicious activity reports (SARs).

Eun Young noted that U.S. financial enforcers may adjust enforcement priorities to align with broader national security goals. She also cautioned that companies may now have to defend decisions not to file SARs, particularly if those decisions are not well documented, and highlighted the added exposure created by a minimum five-year statute of limitations that can be extended in cross-border cases.

Read the full article (subscription required).