FAQs on Suspicious Activity Reporting for Bank Holding Companies

Federal Reserve SR Letters

Published October 10th, 2025

Detected March 13th, 2026

Summary

The Federal Reserve, along with other financial regulators, has issued Frequently Asked Questions (FAQs) to clarify Suspicious Activity Reporting (SAR) requirements for financial institutions. These FAQs aim to assist institutions with their compliance obligations under the Bank Secrecy Act and do not alter existing regulations.

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What changed

The Federal Reserve, in conjunction with other federal financial regulators, has released answers to Frequently Asked Questions (FAQs) concerning Suspicious Activity Reporting (SAR) requirements. This document, SR 25-4, dated October 10, 2025, clarifies existing regulatory obligations for financial institutions supervised by the Board that are subject to SAR requirements under the Bank Secrecy Act. The FAQs are intended to help institutions comply with SAR regulations and focus resources on activities that provide the greatest value to law enforcement.

These FAQs do not introduce new legal or regulatory requirements, nor do they establish new supervisory expectations. Financial institutions should review the FAQs to ensure their current SAR processes align with the clarified guidance. While no specific compliance deadline is mentioned, adherence to SAR requirements is an ongoing legal obligation for all covered institutions. Failure to comply with SAR requirements can lead to penalties under the Bank Secrecy Act.

What to do next

Review the attached FAQs on Suspicious Activity Reporting requirements.
Ensure current SAR processes align with the clarified guidance provided in the FAQs.

Source document (simplified)

Supervision and Regulation Letters

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SR 25-4:

Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551 DIVISION OF
SUPERVISION AND REGULATION

SR 25-4
October 10, 2025 TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK SUBJECT: Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements

This letter applies to all financial institutions supervised by the Federal Reserve that are subject to Suspicious Activity Report (SAR) requirements under the Bank Secrecy Act. 1

The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency and the U.S. Department of the Treasury’s Financial Crimes Enforcement Network are issuing the attached answers to Frequently Asked Questions (FAQs) Regarding Suspicious Activity Reports.

Financial institutions, including those supervised by the Board, have a legal obligation to report suspicious activity. SARs are a cornerstone of the Bank Secrecy Act (BSA) reporting system and are a critical tool for combating financial crimes. The answers to these FAQs clarify regulatory requirements related to SARs and can assist financial institutions with their compliance obligations, while enabling financial institutions to focus resources on activities that produce the greatest value to law enforcement agencies and other government users of BSA reporting. The FAQs do not alter existing BSA legal or regulatory requirements or establish new supervisory expectations.

Reserve Banks should distribute this SR letter to supervised banks in their districts, as well as to supervisory and examination staff. Questions concerning this SR letter or the FAQs may be sent via the Board’s public website. 2

signed by
Mary L. Aiken
Acting Director
Division of
Supervision and Regulation

Attachments:
- Frequently Asked Questions Regarding Suspicious Activity Reporting Requirements (PDF)

Notes:

Financial institutions supervised by the Board subject to the SAR requirements include state member banks (Regulation H, 12 CFR 208.62), Edge and agreement corporations (Regulation K, 12 CFR 211.5(k)), applicable branches, agencies, and representative offices of foreign banking organizations operating in the United States (Regulation K, 12 CFR 211.24(f)), and bank holding companies (Regulation Y, 12 CFR 225.4(f)). Return to text.
See https://www.federalreserve.gov/apps/contactus/feedback.aspx. Return to text. Last Update: October 10, 2025