OCC - Office of Comptroller of Currency
10/09/2025 | Press release | Distributed by Public on 10/09/2025 09:21
Bank Secrecy Act/Anti-Money Laundering: FinCEN Frequently Asked Questions on Suspicious Activity Reporting
Summary
On October 8, 2025, the Office of the Comptroller of the Currency (OCC), 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 Administration issued answers to frequently asked questions (FAQ) related to Suspicious Activity Reports (SAR). The answers to these FAQs clarify regulatory requirements related to SARs and can assist financial institutions with their compliance obligations, while enabling institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of Bank Secrecy Act reporting.
Note for Community Banks
This bulletin is applicable to all community banks.1
Highlights
These FAQs address the following topics:
- SAR filings for potential structuring-related activity
- Continuing activity reviews
- Documentation of decisions not to file a SAR
Further Information
Please contact Melissa Love, Deputy Comptroller for Compliance and Operational Risk, Office of the Chief National Bank Examiner, at (202) 649-6175.
James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner
Related Link
- Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements (PDF)
1 "Banks" refers collectively to national banks, federal savings associations, covered savings associations, and federal branches and agencies of foreign banking organizations. OCC News Release 2025-89 (September 18, 2025) identifies "community banks" as institutions with up to $30 billion in assets.
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