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Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering (AML) Considerations

BSA/AML, OFAC and Fraud
January 19, 2021

Summary:

The FDIC, Board of Governors of the Federal Reserve System, Financial Crimes Enforcement Network, National Credit Union Administration, and Office of the Comptroller of the Currency have issued responses to frequently asked questions (FAQs) regarding suspicious activity reporting and other AML considerations for financial institutions that are required to submit Suspicious Activity Reports (SARs).

Statement of Applicability to Institutions with Total Assets Under $1 Billion: This Financial Institution Letter (FIL) applies to all FDIC-supervised institutions.

Highlights:

  • The agencies jointly developed the attached answers to financial institutions’ commonly asked questions about SARs and AML requirements.
  • The answers clarify SAR/AML requirements in order to assist financial institutions with their compliance obligations and enable them to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of Bank Secrecy Act (BSA) reporting.
  • The FAQs address the following topics: requests by law enforcement to maintain accounts, receipt of grand jury subpoenas and law enforcement inquiries, maintaining customer relationships following the filing of SARs, filing SARs based on negative news media searches, information provided in SAR data and narrative fields, and SAR character limits.
  • The FAQs neither alter existing BSA/AML requirements, nor establish new supervisory expectations.

Distribution:

FDIC-Supervised Institutions

Suggested Routing:

Chief Executive Officer 
BSA Compliance Officer

Additional Related Topics:

  • Anti-Money Laundering
  • Countering the Financing of Terrorism
Attachment(s)
Related Topics
Bank Secrecy Act

Last Updated: January 19, 2021