The Financial Industry Regulatory Authority (“FINRA) recently published an anti-money laundering advisory informing financial institutions that frequently asked questions (“FAQs”) regarding suspicious activity reporting requirements were issued by the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”). The FAQs, which were published on October 9, 2025 (while the U.S. government was shutdown), were issued by FinCEN 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 FAQs were issued to ensure that financial institutions were familiar with SAR compliance obligations, including issues related to the timing of SAR filings, transactions that warrant a filing, and any obligations that might follow a filing. The FAQs also address a financial institution’s decision not to file a SAR. FinCEN also emphasized that none of the answers provided to these FAQs are intended to alter any Bank Secrecy Act requirement or establish new supervisory expectations.
FINRA Rules and Guidance | SAR Frequently Asked Questions