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ARTICLE · 05 NOVEMBER 2025

FinCEN's October SAR FAQs: A Significant Shift

Ankura Consulting Group LLC
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October's interagency Suspiscious Activity Report (SAR) guidance — jointly issued by FinCEN, the Federal Reserve...

United StatesGovernment, Public Sector
Ankura Consulting Group LLC
Ankura Consulting Group LLC

October's interagency Suspiscious Activity Report (SAR) guidance — jointly issued by FinCEN, 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) — may represent a meaningful shift in the Bank Secrecy Act (BSA) / Anti-Money Laundering (AML) compliance practices.

Key Clarifications from the Oct. 9 FAQs

  • No SAR Documentation Required: Financial institutions are not required to document decisions not to file SARs. While this had become a de facto expectation over time, FinCEN now explicitly confirms there is no regulatory requirement.
  • Continuing Activity Reviews: Separate post-SAR reviews to monitor ongoing suspicious activity are not mandated. What began as a suggestion in 2000 had evolved into an examiner expectation, but the guidance clarifies that such reviews are not required.

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