Agencies Issue Clarifying FAQs on Suspicious Activity Reporting
WASHINGTON, October 8, 2025 – Financial institutions received critical guidance today with the release of frequently asked questions (FAQs) concerning Suspicious Activity Reports (SARs).The Office of the Comptroller of the Currency (OCC) issued the FAQs jointly with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the federal Reserve System, the Federal deposit Insurance Corporation, and the National Credit Union Governance.
The new FAQs aim to clarify regulatory requirements surrounding SARs, assisting financial institutions in meeting their Bank Secrecy Act (BSA) compliance obligations.Regulators stated the guidance will also help institutions prioritize resources toward activities that provide the most value to law enforcement and goverment agencies utilizing BSA reporting.
Key areas addressed in the FAQs include:
* SAR filings related to potential structuring activity.
* Processes for continuing activity reviews.
* Requirements for documenting decisions not to file a SAR.
This bulletin is applicable to all community banks.1
Financial institutions seeking further clarification can contact Melissa Love, Deputy Comptroller for Compliance and Operational Risk, Office of the Chief National Bank Examiner, at (202) 649-6175.
The guidance was issued by James M. Gallagher, Senior Deputy Comptroller and Chief National Bank Examiner.
