Suspicious Activity Reports & Continuing Activity
The requirement to file continuing activity SARs has been a very confusing issue which has led to various interpretations over the years. Back in October 2025, FinCEN updated it’s Frequently Asked Questions to address continuing activity SARs. Question #16 addresses the timeline for continuing activity SARs:
FinCEN previously suggested that financial institutions report continuing suspicious activity via a SAR filing at least every 90 days. Subsequent FinCEN guidance advised financial institutions 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, financial institutions are not required to do so and may instead file SARs as appropriate in line with applicable timelines. For financial institutions that elect to file SARs in accordance with FinCEN’s continuing suspicious activity guidance, below is a timeline in which a financial institution files a SAR with an identified subject and determines that suspicious activity has continued:
Day 0: detection of facts that may constitute a basis for filing a SAR
Day 30: filing of initial SAR
Day 120: end of 90-day period
Day 150: filing of a SAR for continued suspicious activity
When filing a SAR for continuing activity, the date or date range of suspicious activity (Item 30 on the SAR form) should include the entire 90-day period starting on the date immediately following the filing of the initial SAR or the date following the end of the previous 90-day period.
Kevin explains more in the video.
Published 2026/05/07
Kevin Edwards
Kevin brings years of experience and a unique perspective on regulatory matters to our clients. A self-proclaimed geek and accredited CRCM, Kevin is also a recovering attorney with experience as in-house counsel for a large regional bank and one of the leading national title insurance providers. For reasons unknown, Kevin decided to leave the safety and serenity of his desk job to seek fortune and glory as a wandering adventurer. Like a bank compliance version of Kwai Chang Caine, The Man with No Name or Don Quixote, he now travels the land seeking to help those in need and righting compliance wrongs, wherever he may find them. Kevin lives in Sioux Falls with his two children, who are surprisingly normal after having endured their father’s vivid imagination for their entire lives. He won’t admit to having any hobbies, because apparently “Regulations never sleep.” (While he does say this in his Batman voice, we’re pretty sure he’s joking.) From the looks of his Facebook page, he likes the outdoors and spending time with his large extended family (who seem like relatively normal people).