Reported by FinCEN

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The U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) has just unleashed a powerful new tool in the fight against global financial crime. On September 5, 2025, FinCEN issued guidance that could transform how banks and financial institutions collaborate across borders. At its core, this guidance encourages voluntary cross-border information sharing, clarifying what can be shared safely without breaching the strict confidentiality rules surrounding Suspicious Activity Reports (SARs).

For decades, financial crime fighters have struggled with fragmented data. Criminals exploit these gaps, moving money across borders faster than regulators or compliance teams can track. By clarifying that the Bank Secrecy Act does not prevent institutions from sharing customer, transaction, and investigative information—even internationally—FinCEN is breaking down silos that have long weakened global defenses. The only restriction that remains absolute is the confidentiality of SARs themselves. But the facts, documents, and records underlying those reports are now clearly fair game for sharing, enabling a far more coordinated approach against money laundering, terrorist financing, and cyber-enabled crime.

The guidance paints a clear picture of what this means in practice. Banks can share data like wire transfers, cash deposit logs, beneficial ownership details, occupation and wealth information, and even cyber identifiers such as IP addresses and geolocations. They can also share due diligence findings, adverse media results, and analytic research that does not explicitly reveal SAR decisions. This means compliance teams on opposite sides of the world can connect dots faster, spotting suspicious patterns before criminals can exploit the cracks. For institutions involved in correspondent banking, this is a game-changing development.

At the same time, FinCEN underscores that confidentiality remains paramount. Financial institutions must be vigilant, using safeguards such as redaction to ensure that nothing shared directly or indirectly reveals the filing of a SAR. And if an institution receives a subpoena or request for a SAR from anyone other than authorized authorities, it must immediately alert FinCEN. This is about smart collaboration, not loosening the rules. Importantly, the guidance does not impose new obligations or compliance standards—it clarifies how institutions can use existing authorities to their fullest advantage.

The bigger picture is profound. This guidance signals a shift from isolated compliance efforts to a more united global strategy. By enabling responsible information sharing, FinCEN is arming financial institutions with a new weapon: collaboration. This is about more than compliance checkboxes—it is about resilience. Stronger data-sharing practices mean stronger AML and CFT programs, more useful intelligence for law enforcement, and a more transparent and secure global financial system.

In today’s interconnected world, financial crime cannot be fought in silos. FinCEN’s guidance makes it clear: collaboration across borders is not just encouraged—it is essential. This is the future of financial crime prevention, and it is a future where criminals will find fewer safe havens to hide.