Regulatory Alerts2025-09-05
Cross-Border Information Sharing by Financial Institutions and SAR Confidentiality
The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in consultation with the OCC, FDIC, and NCUA, issued this guidance to encourage voluntary cross-border information sharing among financial institutions to combat illicit finance. The document clarifies that the Bank Secrecy Act generally does not prohibit sharing underlying facts, transactions, and documents, provided such disclosure does not reveal the existence or non-existence of a Suspicious Activity Report. It further provides examples of permissible information and reminds institutions of their obligation to notify FinCEN if they receive subpoenas or requests for SAR-related data.
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