On 1/19/2021, the FDIC, Federal Reserve, FinCEN, NCUA, and OCC jointly issued responses to frequently asked questions (FAQs) regarding suspicious activity reporting and other AML considerations for financial institutions that are required to submit Suspicious Activity Reports (SARs). Highlights of this joint guidance include:
The agencies jointly developed the attached answers to financial institutions’ commonly asked questions about SARs and AML requirements.
The answers clarify SAR/AML requirements in order to assist financial institutions with their compliance obligations and enable them to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of Bank Secrecy Act (BSA) reporting.
The FAQs address the following topics: requests by law enforcement to maintain accounts, receipt of grand jury subpoenas and law enforcement inquiries, maintaining customer relationships following the filing of SARs, filing SARs based on negative news media searches, information provided in SAR data and narrative fields, and SAR character limits.
The FAQs neither alter existing BSA/AML requirements, nor establish new supervisory expectations.
The FDIC’s version of the FAQs can be found here.