Overview
- FinCEN and the Federal Reserve, FDIC, NCUA, and OCC issued joint SAR FAQs on October 9 clarifying that proximity to the $10,000 CTR threshold alone does not require a SAR.
- The FAQs state there is no mandated separate 90‑day post‑SAR review to check for continued activity and no regulatory requirement to document a decision not to file a SAR.
- Regulators emphasized the guidance does not change underlying SAR rules or supervisory authority, keeping the risk‑based standard tied to knowledge or reasonable suspicion.
- Banks can adjust monitoring, model tuning, alert handling, and documentation now to reduce defensive filings while still reporting genuinely suspicious activity promptly.
- Senate Republicans introduced the STREAMLINE Act on October 21 to lift the CTR threshold to $30,000 and raise certain SAR thresholds with five‑year inflation adjustments, drawing industry and conservative advocacy support but not yet changing the law.