On Oct. 9, 2025, the Financial Crimes Enforcement Network (FinCEN) released four new frequently asked questions (FAQs) clarifying suspicious activity reporting (SAR) requirements, ultimately slightly reducing the Bank Secrecy Act (BSA) burden on compliance departments. The FAQs provide BSA officers with more discretion in SAR decision making and filings, including:

• Mere presence of a transaction(s) at or near the $10,000 Currency Transaction Report (CTR) threshold is not information sufficient to require the SAR filing.
  • They are not required to conduct a separate review following the SAR filing to determine whether suspicious activity has continued.
  • There is no requirement or expectation for a financial institution to document its decision not to file a SAR.
  • There is a relaxed timeline for filing continuing SAR. 

While this is good news since it reduces the BSA burden, it could be viewed as temporary. This guidance can be changed by FinCEN at any time, particularly if there is a change in administrations. 

Doeren Mayhew’s compliance pros will continue to monitor updates to provide institutions with the most current guidance to remain compliant with regulations.