Log in or register
Share on LinkedInShare on LinkedIn

ARTICLE · 19 NOVEMBER 2025

FinCEN And Banking Regulators Issue New FAQs On Suspicious Activity Reports

Crowell & Moring LLP
Crowell & Moring LLP
Contributor
Crowell & Moring LLP

Crowell & Moring LLP

Crowell & Moring’s Doha office is a full service legal practice that serves as the firm’s regional...

View firm profile
Explore more from Crowell & Moring LLP

According to remarks the same day from Treasury Secretary Scott Bessent, the FAQs are intended to reduce the compliance burdens associated with filing SARs without diminishing the benefit of SAR reporting to law enforcement.

United StatesFinance and Banking
Carlton Greene
Carlton Greene
Erik Woodhouse
Erik Woodhouse
Jacqueline (Jackie) Schaeffer
Jacqueline (Jackie) Schaeffer

Banks and other regulated financial institutions have been digesting a set of four frequently asked questions ("FAQs") about suspicious activity reports ("SARs") issued jointly on October 9, 2025 by FinCEN and federal banking regulators (the Board of Governors of the Federal Reserve System, the Office of the Comptroller of the Currency, the Federal Deposit Insurance Corporation, and the National Credit Union Administration).According to remarks the same day from Treasury Secretary Scott Bessent, the FAQs are intended to reduce the compliance burdens associated with filing SARs without diminishing the benefit of SAR reporting to law enforcement.

1. No Categorical Expectation of SARs for Transactions Approaching CTR Threshold

We operate a free-to-view policy, asking only that you register in order to read all of our content. Please login or register to view the rest of this article.

Register for freeORLog in

The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.

View source

Related Articles

Legal Intelligence Newsletters: sign up for the latest legal and regulatory news on your chosen topics

Read more about

Related Comparative Guides

See more popular content from

Article

SEC Advances “Responsible Retailization” Through A Potential Accredited Investor Exam And Potential Regulated Fund Reforms

On September 30, 2026, the Securities and Exchange Commission (SEC) issued two rule proposals and five notices aimed at expanding investors’ access to private markets. The package would add ways to qualify as an accredited investor, including passing a new exam administered by the Financial Industry Regulatory Authority (FINRA), broaden performance-based compensation and modernize regulated funds, including interval funds and business development companies (BDCs).
United StatesFinance and Banking
Proskauer Rose LLP
Proskauer Rose LLP
Article

OCC Issues Examiner Framework For Banks’ Use Of Artificial Intelligence

The Office of the Comptroller of the Currency has released a new framework for evaluating banks' deployment of artificial intelligence and agentic AI systems in their business operations. This guidance establishes how examiners will assess AI through existing risk management disciplines rather than creating separate regulatory requirements, with review intensity scaled to each use case's potential consequences and level of human oversight.
United StatesFinance and Banking
Sheppard
Sheppard
Article

23x5 Trading Comes To US Exchanges: What Firms Should Know Before Launch

US national securities exchanges are preparing to launch 23x5 trading by December 6, 2026, marking the most significant expansion of trading hours in decades. This comprehensive analysis examines the regulatory approvals, operational infrastructure changes, investor protection mechanisms, and issuer considerations necessary to support overnight equity trading from Sunday through Thursday evenings.
United StatesFinance and Banking
WilmerHale
WilmerHale
Article

SEC Proposes Rule Amendments To Expand Retail Access To Private Markets

The SEC has proposed sweeping amendments to expand retail investor access to private market strategies, including changes to performance-based compensation rules for registered investment advisers and modernization of the interval fund framework. The proposals also explore new credential-based pathways for individuals to qualify as accredited investors, potentially opening private offerings to a broader pool of eligible participants.
United StatesFinance and Banking
Duane Morris LLP
Duane Morris LLP
Article

SBA Extends Deadline For Comments On Historic Overhaul Of Size Standards

The Small Business Administration has extended the comment period for two proposed rules that could dramatically reshape federal government contracting by significantly expanding the pool of entities eligible for small business set-aside procurements. With some size standard thresholds proposed to increase as much as tenfold, these changes would fundamentally alter the makeup of the small business contractor base.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

U.S.-China Trade Truce Extended Two Months: BIS Affiliates Rule Suspension Follows

The U.S.-China trade truce has been extended through January 10, 2027, pushing back the effective date of the Bureau of Industry and Security's Affiliates Rule. While the suspension delays immediate compliance obligations, the rule remains in place and companies should use this additional time to prepare their compliance programs before the suspension potentially expires.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

State AG News: Consumer Fraud And Deceptive Practices (October 1-7, 2026)

State attorneys general across the nation are taking decisive legal action on multiple fronts, from challenging federal fuel economy rollbacks to pursuing pharmaceutical companies over misleading drug claims. This week's enforcement activities reveal coordinated multistate efforts alongside individual state actions targeting consumer protection, national security concerns, and social media platform accountability.
United StatesGovernment, Public Sector
Crowell & Moring LLP
Crowell & Moring LLP
Article

White House Announces AI Responsibility Accord, Executive Orders, And Super Intelligence Task Force

The Trump Administration has introduced a voluntary regulatory framework for artificial intelligence through the White House Accord on Super Intelligence, signed by six leading tech companies. This new approach emphasizes corporate self-policing with safety audits and board oversight, while simultaneously rebranding government AI terminology and establishing a new interagency coordination force. How will this light-touch regulatory strategy balance innovation with mounting safety concerns as AI capabilities
United StatesStrategy
Crowell & Moring LLP
Crowell & Moring LLP
Article

The Lindsey Graham Sanctions Act: What Businesses Need To Know About The New Tariffs

President Trump signed the Lindsey O. Graham Sanctioning Russia and Iran Act into law on September 18, 2026, establishing mandatory tariffs of up to 500% on Russian goods and up to 100% on goods from countries that continue to buy Russian energy. The Act targets major importers like China, India, and Turkey, with limited relief mechanisms including natural gas exceptions, presidential waivers, and a 270-day winddown period for entities divesting from Russian operations.
GlobalInternational Law
Crowell & Moring LLP
Crowell & Moring LLP
Article

Proposed AI Governance Framework: Risk-Mitigation Recommendations For Health Plans

Senator Maria Cantwell has proposed a comprehensive AI governance framework that could fundamentally reshape how health insurance plans deploy artificial intelligence in prior authorization and utilization management. With explicit focus on CMS's WISeR model and requirements for meaningful human oversight, the framework signals potential federal mandates that would require health plans to audit AI systems, ensure transparency in consequential decisions, and maintain accountability for AI-related harms.
United StatesFood, Drugs, Healthcare, Life Sciences
Crowell & Moring LLP
Crowell & Moring LLP
Article

California Follows New York’s Lead In Requiring AI “Synthetic Performer” Disclosures In Advertising

California has enacted SB 1050, requiring advertisers to disclose when AI-generated synthetic performers appear prominently in advertisements starting January 1, 2027. The law mandates clear disclosures using specific language and creates enforcement mechanisms through existing consumer protection statutes, while also imposing obligations on advertising platforms to remove non-compliant content after court orders.
United StatesMedia, Telecoms, IT, Entertainment
Crowell & Moring LLP
Crowell & Moring LLP
Article

DOT Final Rule Narrows Airline Delay And Cancellation Reporting Obligation Under FAA Reauthorization Act Of 2024

The U.S. Department of Transportation has issued a final rule fundamentally restructuring how airlines report flight delays and cancellations, creating a new reporting category that removes ten specific events from the traditional "Air Carrier" category. This regulatory change, mandated by the FAA Reauthorization Act of 2024 and effective October 2026, will significantly impact how airline performance is measured and perceived by consumers, while reducing carriers' customer service obligations for certain
United StatesTransport
Crowell & Moring LLP
Crowell & Moring LLP
Article

California’s “No Robo Bosses Act” Is Now Law: Human Oversight Required For AI-Driven Discipline And Termination

California's new "No Robo Bosses Act" (SB 947) prohibits employers from relying solely on artificial intelligence or automated decision systems when disciplining or terminating employees, requiring meaningful human review and written notice to affected workers. The law, effective July 1, 2027, establishes strict compliance requirements including corroboration protocols, employee data access rights, and anti-retaliation protections that will fundamentally reshape how California employers deploy AI-driven wor
United StatesEmployment and HR
Crowell & Moring LLP
Crowell & Moring LLP