Reported by Claire Williams
(Excerpt shared below. To read full report and the SAR FAQ from FinCEN, go to: https://www.americanbanker.com/news/exclusive-regulators-move-to-ease-banks-sar-burden and https://www.fincen.gov/system/files/2025-10/SAR-FAQs-October-2025.pdf)
New guidance obtained by American Banker would reduce the number of suspicious activity reports, or SARs, banks are required to file, a move aimed at easing banks’ compliance burden and making data more useful for law enforcement.
The Treasury Department, Federal Reserve, Federal Deposit Insurance Corp. and Office of the Comptroller of the Currency are releasing a new Frequently Asked Questions guidance document that is meant to cut the compliance burden for banks and other financial firms by reducing the number of SARs that they need to file.
The new guidance from the banking regulators should ease some of those worries.
The FAQs don’t change anti-money laundering legal or regulatory requirements, or establish new expectations, Treasury said. But the new guidance does tells banks that they do not necessarily need to file SARs for transactions or a series of transactions at or near the $10,000 currency transaction reporting, or CTR, threshold — the point at which banks must file a separate report with Fincen. Financial firms only need to file a SAR if the institution has reason to suspect that the transaction or series of transactions is designed to evade CTR.
The regulators also said that financial institutions aren’t required to conduct a separate review of a customer or account after filing a SAR to see if suspicious activity has continued, and that there’s no requirement for financial institutions to document the decision to not file a SAR.
The move is part of the Treasury Department’s ongoing effort to simplify the BSA process, particularly around SARs.