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FinCEN, OCC Explain SAR Requirements

U.S. regulators issued guidance Thursday in a bid to clarify when banks and other financial services companies must file, or should consider filing, suspicious activity reports, or SARs, on customers or transactions.

The Federal Reserve, Office of the Comptroller of the Currency, Financial Crimes Enforcement Network and other federal regulators explain in the guidance that cash deposits and withdrawals “at or near” the $10,000 threshold for filing currency transaction reports do not require a SAR unless they appear intentionally structured below that amount.

Moreover, financial institutions are under no obligation to review, manually or otherwise, accounts and customers on whom they previously filed SARs to assess whether the initial activity that raised suspicion persisted afterwards, according to the guidance, which regulators issued in response to frequently asked questions.

Moneylaundering.com may update this coverage as more information becomes available.
Topics : Anti-money laundering , Counterterrorist Financing , Fraud
Source: U.S.: FinCEN
Document Date: October 9, 2025