Compliance Update — Insights And Highlights October 2025

Recently, the Financial Crimes Enforcement Network (FinCEN), the Federal Reserve, the Federal Deposit Insurance Corp., the National Credit Union Administration, and the Office of the Comptroller of the Currency (collective, the Agencies) issued responses to four frequently asked questions (FAQ) related to Suspicious Activity Report (SAR) requirements. The questions and answers are related to structuring SARs, continuing SARs, and documentation of decisions not to file SARs.

First, the Agencies clarified that a financial institution is not required to file a SAR for a transaction or series of transactions for structuring unless the institution knows, suspects, or has reason to suspect that the transaction or series of transactions is designed to evade Currency Transaction Report (CTR) requirements. In other words, if a transaction is picked up in monitoring simply for being just at or under the $10,000 CTR threshold and for no other reasons, then a SAR may not be