FinCEN & Regulators Update SAR FAQs for Financial Institutions

The FAQs aim to clarify compliance expectations for financial institutions under the Bank Secrecy Act (BSA). 

Key points include: 

➡️ Structuring Activity: Firms only need to file SARs for transactions at or near the $10,000 Currency Transaction Report (CTR) threshold when evasion is suspected. 

➡️ AML/CFT Controls: Firms must operate risk-based AML/CFT programs capable of detecting and reporting suspicious activity.  

➡️ Continuing Activity: Post-SAR reviews aren’t required; firms should rely on risk-based monitoring instead.  

➡️ SAR Documentation: Documenting SAR non-filings isn’t mandatory, though brief internal notes documenting the rationale are recommended. 

✅ Firms should align AML/CFT frameworks with FinCEN’s updated SAR guidance, focusing on risk-based monitoring, effective escalation, and proportionate documentation.