SAR FAQs: Continuing Activity Review

As we previously mentioned, FinCEN along with the FDIC, Federal Reserve, NCUA, and OCC, provided answers to four Frequently Asked Questions (FAQs) about Suspicious Activity Reports (SARs).

Two of those questions had to do with continuing activity reviews:

• Is a financial institution required to conduct a review of a customer or account following the filing of a SAR to determine whether suspicious activity has continued?
• What is the timeline for a financial institution that elects to file SARs in accordance with FinCEN’s continuing suspicious activity guidance?

FinCEN clarified that, after filing a SAR, institutions are NOT required to conduct a separate review to determine whether the suspicious activity has continued. FinCEN guidance from October 2000 suggested ...that institutions file a SAR for repeated and ongoing suspicious activity at least every 90 days. Over time, this has been misinterpreted as a requirement or expectation to ...conduct a separate review of a customer or account following the filing of a SAR...

FinCEN also previously issued guidance to ...file SARs for continuing activity after a 90-day period with the filing deadline being 120 calendar days after the date of the previously related SAR filing. However, the FAQ points out that ...financial institutions are not required to do so and may instead file SARs as appropriate in line with applicable timelines.

Kevin explains more in the video:

We addressed each of these SAR FAQs in more detail in the November 2025 issue of Banking on BCC. So be sure to check it out!

Published
2025/11/24