NCUA, agencies answer SAR questions to reduce compliance burdens

October 10, 2025

Working to ensure financial institutions aren’t expending resources on efforts that don’t help law enforcement, the Financial Crimes Enforcement Network (FinCEN) issued answers to four frequently asked questions to clarify suspicious activity report (SAR) requirements. FinCEN issued the FAQs jointly with the NCUA and other federal financial regulators.

America’s Credit Unions has regularly engaged FinCEN on the need to modernize SARs and Currency Transaction Reports (CTR) to maximize usefulness for law enforcement while reducing compliance burdens for credit unions. Its compliance team will examine the FAQs in detail in an upcoming blog post.

“SARs should deliver better outcomes by providing law enforcement the most useful information—not by overwhelming the system with noise,” said Under Secretary for Terrorism and Financial Intelligence John K. Hurley. “Compliance requires real resources, and that’s why prioritization is crucial. At Treasury, we will continue to reform our Anti-Money Laundering and Countering the Financing of Terrorism framework to deprioritize low-value activity and direct compliance resources towards the most significant threats to our country.”

The FAQs clarify:

  • Being close to or at the $10,000 CTR threshold is not enough to require a SAR. There must be knowledge, suspicion, or reason to believe the transaction is structured to evade CTR reporting;
  • Regarding continuing activity reports, separate reviews of members and/or accounts following a SAR filing are not required to determine whether suspicious activity has continued. SAR filers may rely on risk-based internal policies, procedures, and controls to monitor and report on-going suspicious activity, as appropriate.
  • For those that elect to follow FinCEN’s continuing activity guidance, the date or date range of suspicious activity should include the entire 90-day period starting on the date immediately following the initial SAR filing, or the date following the end of the previous 90-day period. Note that the guidance makes clear that financial institutions are not required to follow the continuing activity guidance and may instead file SARs as appropriate in line with applicable timelines; and
  • BSA regulations do not require that filers document decisions not to file a SAR. Doing so is optional (though encouraged in more complex cases).

Read the FAQs here