On October 9th, FinCEN provided answers to four Frequently Asked Questions (FAQs) regarding Suspicious Activity Reports (SARs). FinCEN stated it wants to ensure financial institutions are not needlessly expending resources on efforts that do not provide law enforcement and national security agencies with the critical information they need to detect, combat, and deter criminal activity.
Clarification was provided for the following questions:
- Is a financial institution required to file a SAR for a transaction or a series of transactions with a value at or near the currency transaction reporting (CTR) threshold (i.e., over $10,000) absent information that the transaction or series of transactions is designed to evade BSA reporting requirements?
- 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?
- Is a financial institution required to document the decision not to file a SAR?
Kevin Edwards will be addressing the FAQs in more detail during the AML/CFT Memebrship Group.
Published
2025/10/15
