money laundering and related financial crimes." In the development of that strategy, the legislation gives a list of areas that address any area the President, acting through the Secretary and in consultation with the Attorney General, considers appropriate. Section 354 added a new area to be addressed in the strategy: "Data concerning money laundering efforts related to the funding of acts of international terrorism, and efforts directed at the prevention, detection, and prosecution of such funding". Sec. 355. Written employment references and illegal activity The Federal Deposit Insurance Act was amended to allow written employment references to contain suspicions of involvement in illegal activity in response to a request from another financial institution. The amendment makes clear that it allows such disclosures but does not require it, and also makes clear that the amendment does not shield from liability anyone who makes a disclosure that is found to have been made with malicious intent. Sec. 356. Reporting suspicious activities of brokers and dealers Section 356 deals with suspicious activity reports (SARs). Part (a) states that the Secretary of Treasury was required to create regulations that require brokers and dealers registered with the Securities and Exchange Commission under the Securities Exchange Act of 1934 to submit suspicious activity reports under section 5318(g) of title 31, United States Code. The regulations filed were 31 CFR 103.11(ii), which amended the definition of a transaction to encompass any instrument within the definition of security in the Securities Exchange Act of 1934, and 31 CFR 103.19, which requires suspicious transactions over $US5,000 be reported to FinCEN. 31 CFR 103.19 provides details on filing procedures, details several exceptions to the filing requirement and specifies that records must be retained for a period of 5 years by dealer-brokers. It also requires that reports made to FinCEN remain confidential and gives limited liability to the reporting broker-dealer for any disclosures to appropriate authorities. Failure to file reports may be a violation of the BSA. Part (b) of the section states that the Secretary of Treasury may prescribe regulations requiring futures commission merchants, commodity trading advisors and commodity pool operators registered under the Commodity Exchange Act to submit suspicious activity reports. Investment company study Part (c) specified that a report be produced jointly by the Secretary of Treasury, the Board of Governors of the Federal Reserve System, and the Securities and Exchange Commission with recommendations for effective regulations to