NCUA, along the Financial Crimes Enforcement Network (FinCEN), and other federal regulators in consultation with staff from other federal agencies, have issued responses to frequently asked questions on suspicious activity reporting and other anti-money laundering (AML) requirements. A detailed analysis can be found on CUNA's CompBlog.

These FAQs clarify the regulatory requirements related to suspicious activity reporting to 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 Bank Secrecy Act (BSA) reporting.

The FAQs address questions about

• Maintaining accounts at the request of law enforcement;
• SAR filing and the receipt of grand jury subpoenas or other law enforcement inquiries;
• Maintaining customer relationships following the filing of a SAR;
• SAR filing and monitoring on negative media alerts;
• Data fields;
• The SAR narrative; and
• SAR character limits.

These FAQs do not alter existing BSA/AML legal or regulatory requirements and they do not establish new supervisory expectations.

These FAQs were developed in response to recent Bank Secrecy Act Advisory Group recommendations, as described in more detail in FinCEN’s Advance Notice of Proposed Rulemaking on Anti-Money Laundering Program Effectiveness(opens new window), published in September 2020.