Regulatory AlertsSR 21-2: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
The Board of Governors of the Federal Reserve System, alongside other federal banking agencies and FinCEN, issued this guidance to clarify Suspicious Activity Report filing requirements and anti-money laundering compliance processes. The document provides answers to industry questions derived from discussions within the Bank Secrecy Act Advisory Group, aiming to enhance understanding of existing legal obligations without altering regulatory standards. Federal Reserve Banks are instructed to distribute this letter to supervised institutions to ensure consistent application of these clarifications across their districts.
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SR 21-2: Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551
DIVISION OF SUPERVISION AND REGULATION
SR 21-2
January 19, 2021
TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK
SUBJECT:
Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
Applicability: This guidance applies to all financial institutions supervised by the Federal Reserve that are subject to the Bank Secrecy Act.
The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the federal banking agencies) and the U.S Department of the Treasury's Financial Crimes Enforcement Network are issuing the attached Answers to Frequently Asked Questions (FAQs) Regarding Suspicious Activity Reports (SARs) and Other Anti-Money Laundering (AML) Considerations.
Financial institutions, including those supervised by the Federal Reserve 1 , have a legal obligation to report suspicious activity. SARs are a cornerstone of the Bank Secrecy Act (BSA) reporting system, and are a critical tool for combating financial crimes. The FAQs are intended to provide clarity to industry questions regarding certain SAR filing requirements and compliance processes. The FAQs have been issued as a result of discussions among law enforcement, regulators, and industry representatives through the Bank Secrecy Act Advisory Group. The FAQs do not alter existing BSA/AML legal or regulatory requirements, or establish new supervisory expectations.
Federal Reserve Banks are asked to distribute this letter to the supervised institutions in their districts and to appropriate supervisory staff. In addition, supervised organizations may send questions regarding the FAQs via the Board's public website. 2
signed by Michael Gibson Director Division of Supervision and Regulation
Attachments:
Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations
Notes:
The Federal Reserve supervises bank holding companies, which have a regulatory obligation to report suspicious activity under 12 CFR 225.4(f) (Regulation Y). Accordingly, the SAR FAQs may be relevant in part to bank holding companies. Return to text.
See, http://www.federalreserve.gov/apps/contactus/feedback.aspx . Return to text.
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Last Update: January 21, 2021