Advisory: Treasury Issues Frequently Asked Questions to Clarify Suspicious Activity Reporting Requirements

FINRA is issuing this advisory to highlight frequently asked questions (FAQs) issued by the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) related to suspicious activity reports (SARs) to assist financial institutions with their compliance obligations. FinCEN issued the FAQs jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency.

The Oct. 9, 2025, FAQs address whether a financial institution is required to file a SAR for a transaction or a series of transactions with a value at or near the currency transaction reporting threshold; whether a financial institution is required to conduct a review of a customer or account following the filing of a SAR to determine whether suspicious activity has continued, and the timeline for SAR filings for financial institutions that elect to do so; and whether a financial institution is required to document the decision not to file a SAR. FinCEN stated that “[t]he answers to these FAQs do not alter existing BSA [Bank Secrecy Act] legal or regulatory requirements or establish new supervisory expectations.” 

The FAQs are available on FinCEN’s website.

If you have general questions about this advisory, please contact FINRA’s Office of General Counsel by email or at (301) 590-6500 (calls will be routed through the FINRA Support Center).