The Financial Crimes Enforcement Network (FinCEN), in coordination with four major U.S. banking regulators, has released a set of frequently asked questions (FAQs) aimed at clarifying how financial institutions should comply with suspicious activity reporting (SAR) requirements under the Bank Secrecy Act (BSA).
The guidance, jointly issued with the Federal Reserve, the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC), seeks to streamline compliance expectations and help firms focus their anti-money laundering and counter-terrorist financing (AML/CFT) resources on activity that offers the greatest value to law enforcement.
FinCEN emphasized that the FAQs are clarifications, not changes to law or regulation. “These answers do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations,” the agency stated. Instead, the document aims to address ongoing industry uncertainty regarding SAR filing practices and reporting obligations.
Suspicious Activity Reports are a critical tool in the U.S. government’s efforts to combat financial crime. Banks and other financial institutions are required to file SARs when they detect transactions linked to money laundering, fraud, organized crime, human trafficking, terrorist financing, or other illicit activity. However, financial institutions have long raised concerns about the volume and complexity of SAR filings, often claiming they are burdened by duplicative or unclear reporting expectations.
By issuing clearer guidance, FinCEN and its partner regulators say they hope to help compliance teams better prioritize their resources. The FAQs are designed to ensure consistent regulatory interpretation while reducing unnecessary or low-value filings that consume both time and manpower.
The move comes amid a broader push by U.S. regulators to modernize the nation’s AML/CFT regime. This includes implementation of the Anti-Money Laundering Act of 2020, expanded corporate transparency rules, and renewed focus on emerging financial threats such as digital assets and cyber-enabled fraud.
While financial institutions have welcomed efforts to clarify expectations, regulatory agencies reiterated that SAR reporting remains a legal obligation. Institutions are still required to maintain robust internal controls, monitor customer behavior, and promptly report suspicious transactions. The new FAQs are meant to assist compliance—not reduce accountability.
FinCEN said the guidance aligns with its goal of promoting “effective, risk-based AML/CFT programs” across the U.S. financial system. The FAQs are expected to be incorporated into ongoing supervisory discussions and examinations, offering compliance officers new reference material for training and risk management.
The full FAQ document can be accessed below.
By FCCT Editorial Team
