Regulatory AlertsSR 25-4: Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
The Board of Governors of the Federal Reserve System, along with other federal financial regulators, issued this letter to provide clarifying answers to frequently asked questions regarding Suspicious Activity Report (SAR) requirements. The guidance aims to assist financial institutions in meeting their legal obligations under the Bank Secrecy Act by clarifying regulatory expectations without altering existing laws or establishing new supervisory standards. Reserve Banks are instructed to distribute this letter to supervised banks and examination staff to help institutions focus resources on activities that provide the greatest value to law enforcement.
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SR 25-4: Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
BOARD OF GOVERNORS OF THE FEDERAL RESERVE SYSTEM WASHINGTON, D.C. 20551
DIVISION OF SUPERVISION AND REGULATION
SR 25-4
October 10, 2025
TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK
SUBJECT:
Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements
This letter applies to all financial institutions supervised by the Federal Reserve that are subject to Suspicious Activity Report (SAR) requirements under the Bank Secrecy Act. 1
The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency 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.
Financial institutions, including those supervised by the Board, 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 answers to these FAQs clarify regulatory requirements related to SARs and can assist financial institutions with their compliance obligations, while enabling financial institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of BSA reporting. The FAQs do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations.
Reserve Banks should distribute this SR letter to supervised banks in their districts, as well as to supervisory and examination staff. Questions concerning this SR letter or the FAQs may be sent via the Board’s public website. 2
signed by Mary L. Aiken Acting Director Division of Supervision and Regulation
Attachments:
Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements (PDF)
Notes:
Financial institutions supervised by the Board subject to the SAR requirements include state member banks (Regulation H, 12 CFR 208.62), Edge and agreement corporations (Regulation K, 12 CFR 211.5(k)), applicable branches, agencies, and representative offices of foreign banking organizations operating in the United States (Regulation K, 12 CFR 211.24(f)), and bank holding companies (Regulation Y, 12 CFR 225.4(f)). Return to text.
See https://www.federalreserve.gov/apps/contactus/feedback.aspx . Return to text.
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Last Update: October 10, 2025