On October 9, 2025, FinCEN issued answers to four Frequently Asked Questions to clarify certain requirements related to suspicious activity reports (SARs). The FAQs were issued jointly with the Board, the FDIC, the NCUA, and the OCC.

The FAQs clarify questions regarding SAR filings for potential structuring-related activity, continuing activity reviews, timeline for continuing activity reviews, and no SAR documentation. The guidance is intended to help financial institutions meet their compliance obligations, allowing them to allocate resources more effectively towards activities that generate the most significant value for law enforcement agencies and other authorized government users of Bank Secrecy Act (BSA) reporting. FincEN clarified that the FAQs do not change the current BSA legal or regulatory requirements and do not create new supervisory expectations.

Read FinCEN’s press release here.

The SAR FAQs can be found here.

Adam Witmer

Adam Witmer is a speaker, author, and founder of the Compliance Cohort. Adam has taught hundreds of seminars and training sessions to thousands of bankers throughout the United States and teaches on all areas of regulatory compliance. Adam has written five e-books that he never published, hit a grizzly bear while driving in a National Park, and is an award winning photographer and musician (though he no longer takes photos nor plays any instruments). In his spare time, Adam can be found kayaking on the lake, doing taekwondo with his kids, working on his (project) house, or spending time with his family.

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