FinCEN Issues FAQs Clarifying Suspicious Activity Reporting (SAR) Requirements

The Financial Crimes Enforcement Network (FinCEN) of the US Department of the Treasury has issued new guidance to clarify key elements of Suspicious Activity Report (SAR) obligations for financial institutions. Published on 9 October 2025, the Frequently Asked Questions (FAQs) aim to help firms comply more effectively with Anti-Money Laundering and Countering the Financing of Terrorism (AML/CFT) requirements, while ensuring that reporting delivers genuine value to law enforcement.

Developed jointly with the Federal Reserve, Federal Deposit Insurance Corporation, National Credit Union Administration and the Office of the Comptroller of the Currency, the FAQs address common challenges around structuring SARs, managing continuing activity reviews, and documenting decisions not to file a SAR. The guidance is informed by extensive feedback from the financial sector.

Under Secretary for Terrorism and Financial Intelligence John K Hurley emphasised the importance of focusing resources on meaningful intelligence:

SARs should deliver better outcomes by providing law enforcement the most useful information—not by overwhelming the system with noise. Compliance requires real resources, and that’s why prioritisation is crucial.

FinCEN’s initiative forms part of a wider Treasury effort to modernise the AML/CFT regime by reducing low-value reporting and encouraging targeted, risk-based compliance. The FAQs are intended to support financial institutions across all regulated sectors—including banks, credit unions, money service businesses, insurance companies, mortgage lenders, casinos, and dealers in precious metals or securities—in refining their SAR procedures.

Read the press release here.