FinCEN, FED, FDIC, NCUA and OCC Issue FAQs Regarding SARs

On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN), jointly with the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration (NCUA), and the Office of the Comptroller of the Currency (OCC), issued answers to frequently asked questions (FAQs) regarding suspicious activity reports (SARs) and other anti-money laundering/countering the financing of terrorism (AML/CFT) considerations for financial institutions covered by SAR rules.

Although the answers to these FAQs do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations, the answers are intended to clarify regulatory requirements related to SARs.

Financial institutions subject to SAR requirements include: Banks, Casinos and Card Clubs, Money Services Businesses, Brokers or Dealers in Securities, Mutual Funds, Insurance Companies, Futures Commission Merchants and Introducing Brokers in Commodities, Loan or Finance Companies, and Housing Government Sponsored Enterprises.

Investment advisers will be required to establish and implement anti-money laundering (AML) programs

NOTE: Investment advisers were scheduled to become subject to Suspicious Activity Report (SAR) reporting on January 1, 2026, but the U.S. Department of the Treasury's Financial Crimes Enforcement Network (FinCEN) announced a proposal to delay this effective date to January 1, 2028. Investment advisers will be required to establish and implement anti-money laundering (AML) programs, which include procedures for ongoing customer due diligence and the filing of SARs for transactions they suspect involve illicit financial activity.

The bulletin is available HERE