News & Analysis as of

BSA/AML Suspicious Activity Reports (SARs)

Mayer Brown

FinCEN Publishes FAQs to Reduce Certain Compliance Burdens Associated with SAR Filings

Mayer Brown on

On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”), jointly with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the...more

Frost Brown Todd

Bill Introduced to Increase Reporting Thresholds Under the Bank Secrecy Act

Frost Brown Todd on

On October 21, 2025, the Senate Committee on Banking, Housing, and Urban Affairs introduced S.B. 3017, titled the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act...more

Bradley Arant Boult Cummings LLP

Less Noise, More Signal: What FinCEN’s New SAR Guidance and the STREAMLINE Act Could Mean for BSA Reporting

Two recent developments signal that momentum is building in Washington to recalibrate Bank Secrecy Act (BSA) reporting to produce higher‑value intelligence with less compliance friction. First, on October 9, 2025, the...more

Ballard Spahr LLP

FinCEN Releases Data Showing $9 Billion in Iranian Shadow Banking Activity

Ballard Spahr LLP on

On October 23, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) issued a Financial Trend Analysis (“FTA”), identifying $9 billion of potential Iranian shadow banking activity in...more

McGuireWoods LLP

Reducing BSA Compliance Obligations? A Look at the Senate’s STREAMLINE Act

McGuireWoods LLP on

The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and...more

WilmerHale

FinCEN Clarifies Suspicious Activity Reporting Requirements

WilmerHale on

On October 9, 2025, the US Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) and the prudential regulators issued joint guidance clarifying regulatory expectations for suspicious activity reports...more

Sheppard Mullin Richter & Hampton LLP

OCC Settles with Bank Over Alleged BSA/AML Violations

On October 16, the OCC announced a formal agreement with a national bank in Florida for alleged unsafe or unsound practices related to board oversight, corporate governance, strategic and capital planning, and compliance with...more

Orrick, Herrington & Sutcliffe LLP

OCC announces enforcement actions for October 2025, including one formal agreement

On October 16, the OCC announced enforcement actions for October, including one new formal agreement and four terminations of prior agreements. The OCC entered into a formal agreement with a national bank in September after...more

McGuireWoods LLP

FinCEN Eyes Easing Compliance Burdens on Financial Institutions

McGuireWoods LLP on

The Financial Crimes Enforcement Network (“FinCEN”) has recently taken two steps in furtherance of the Trump Administration’s deregulatory agenda.  ...more

Benesch

The “Streamline Act” Seeks to Raise Reporting Thresholds and Modernize the Bank Secrecy Act

Benesch on

On October 21, 2025, U.S. Senators unveiled a bill that would increase reporting thresholds for currency transaction reports (“CTRs”) and suspicious activity reports (“SARs”) under the Bank Secrecy Act (“BSA”)....more

Ballard Spahr LLP

Suspicious Activity Reports – What New Guidance Means for Financial Institutions

Ballard Spahr LLP on

On October 9, 2025, the Financial Crimes Enforcement Network (“FinCEN”) jointly issued updated Frequently Asked Questions (“FAQs”) with the Federal Reserve Board of Governors, the Federal Deposit Insurance Corporation, the...more

Brownstein Hyatt Farber Schreck

FinCEN Seeks to Clarify Suspicious Activity Reporting Obligations Under the BSA

The Federal Crimes Enforcement Network (FinCEN) recently issued some rare, detailed guidance concerning the filing of Suspicious Activity Reports (SARs), impacting how financial institutions and larger casinos comply with...more

Clark Hill PLC

Anti-Money Laundering Rules: Ethical Requirements for Attorneys as Reporting Persons

Clark Hill PLC on

This article explains the requirements of a new anti-money laundering rule that, when effective on March 1, 2026, will require suspicious activity reporting from advisors (including attorneys) who assist clients with certain...more

Morrison & Foerster LLP

FinCEN Streamlines SAR Guidance: New FAQs Focus on Risk-Based AML Compliance

Morrison & Foerster LLP on

On October 9, 2025, the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCEN) jointly with the Board of Governors of the Federal Reserve System (Federal Reserve), the Federal Deposit Insurance...more

King & Spalding

FinCEN Relaxes Suspicious Activity Reporting Requirements Via Four New FAQs

King & Spalding on

On October 9, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN), along with the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National...more

Orrick, Herrington & Sutcliffe LLP

FinCEN Issues FAQs Clarifying SAR Reporting Requirements

On October 9, 2025, the Financial Crimes Enforcement Network (FinCEN), along with the banking and credit union regulators, issued guidance in the form of frequently asked questions (FAQs) addressing the regulatory...more

Troutman Pepper Locke

Navigating the Latest SAR FAQs

Troutman Pepper Locke on

On October 8, the Office of the Comptroller of the Currency (OCC), in collaboration with the Financial Crimes Enforcement Network (FinCEN), the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance...more

Nutter McClennen & Fish LLP

Nutter Bank Report: September 2025

The OCC has announced actions it is taking to eliminate alleged politicized or unlawful debanking in the federal banking system in response to President Trump’s Executive Order 14331, titled Guaranteeing Fair Banking For All...more

Ballard Spahr LLP

How Chinese Money Laundering Networks Are Powering Mexican Cartels: Key Risks and Compliance Strategies for Financial Institutions

Ballard Spahr LLP on

On August 28, 2025, the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (“FinCEN”) released an advisory (FIN-2025-A003) alongside a comprehensive Financial Trend Analysis (“FTA”), shining a spotlight on...more

Orrick, Herrington & Sutcliffe LLP

Treasury’s Hurley favors a less burdensome, outcome-based compliance process

At a September 17 conference, Treasury Under Secretary for Terrorism and Financial Intelligence John Hurley called for modernizing the Bank Secrecy Act (BSA) to ensure financial institutions provide only “highly useful”...more

Moore & Van Allen PLLC

FinCEN Formally Proposes a 2 Year Delayed Effectiveness of Bank Secrecy Act Compliance Obligations for Certain Investment Advisers

Moore & Van Allen PLLC on

Following up and consistent with public statements earlier this summer, FinCEN has formally proposed a two year delay of the effective date of its 2024 final rule that subjects certain investment advisers to the requirements...more

Thomas Fox - Compliance Evangelist

Regulatory Ramblings: Episode 78 - How Well Does the Money Laundering Control System Work? Spotlight on: Rethinking AI Regulation:...

The podcast begins with a brief conversation between Oonagh and Regulatory Ramblings host Ajay Shamdasani about her September 8, 2025, LinkedIn article, “Rethinking AI Regulation: Why Current Approaches Are Falling Short.” ...more

Cooley LLP

OCC Bulletins Announce Plans to Eliminate Debanking

Cooley LLP on

On September 8, the Office of the Comptroller of the Currency (OCC) issued two bulletins aimed at eliminating “politicized or unlawful debanking” by the banks it supervises. The OCC’s guidance is “consistent with” President...more

Orrick, Herrington & Sutcliffe LLP

FinCEN director signals AML reporting reform and highlights priorities in congressional testimony

On September 9, FinCEN Director Andrea Gacki testified before the House Financial Services Subcommittee on National Security, Illicit Finance, and International Financial Institutions, regarding FinCEN’s ongoing efforts to...more

Orrick, Herrington & Sutcliffe LLP

FinCEN issues guidance on cross-border information sharing for financial institutions

On September 5, FinCEN, in consultation with the FDIC, NCUA and the OCC, issued guidance to encourage the voluntarily cross-border sharing of information among financial institutions. ...more

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