Regulatory Alerts2025-10-09
Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
FinCEN and four federal banking regulators issued FAQs to clarify suspicious activity reporting (SAR) obligations for financial institutions without altering existing legal requirements. The guidance specifies that institutions are not required to file SARs for transactions near the $10,000 threshold absent evidence of structuring, nor must they conduct separate continuing activity reviews or document decisions not to file SARs. Institutions may instead rely on risk-based internal controls to monitor and report suspicious activity in accordance with applicable filing timelines.
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