FinCEN Clarifies Aspects of SAR Requirements

On 9 October 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), in concert with other US governmental regulatory agencies, clarified certain requirements related to suspicious activity reports (SARs) by issuing answers to four frequently asked questions (FAQs).

The FAQs address matters pertaining to SAR filings for potential structuring-related activity, continuing activity reviews, and a financial institution’s decision not to file a SAR.