Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements

The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency and the U.S. Department of the Treasury's Financial Crimes Enforcement Network are issuing the attached answers to Frequently Asked Questions (FAQs) Regarding Suspicious Activity Reports.

Financial institutions, including those supervised by the Board, have a legal obligation to report suspicious activity. SARs are a cornerstone of the Bank Secrecy Act (BSA) reporting system and are a critical tool for combating financial crimes. The answers to these FAQs clarify regulatory requirements related to SARs and can assist financial institutions with their compliance obligations, while enabling financial institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of BSA reporting. The FAQs do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations.

Reserve Banks should distribute this SR letter to supervised banks in their districts, as well as to supervisory and examination staff. Questions concerning this SR letter or the FAQs may be sent via the Board's public website.²