Regulatory Alerts2025-10-10 | FIL-48-2025Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
FinCEN, jointly with the Federal Reserve, FDIC, NCUA, and OCC, issued guidance clarifying Suspicious Activity Report (SAR) filing obligations for financial institutions. The document establishes that transactions near the $10,000 currency transaction reporting threshold do not automatically trigger a SAR unless designed to evade reporting requirements. It further eliminates the mandatory 90-day continuing activity review, permits flexible filing timelines for ongoing suspicious activity, and confirms that documenting non-filing decisions remains optional.
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