Supervision and Regulation Letters

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SR 21-2:

Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations

BOARD OF GOVERNORS
OF THE FEDERAL RESERVE SYSTEM
WASHINGTON, D.C. 20551

DIVISION OF
SUPERVISION AND REGULATION

SR 21-2
January 19, 2021

TO THE OFFICER IN CHARGE OF SUPERVISION AT EACH FEDERAL RESERVE BANK

SUBJECT:

Answers to Frequently Asked Questions Regarding Suspicious Activity Reporting and Other Anti-Money Laundering Considerations

Applicability:  This guidance applies to all financial institutions supervised by the Federal Reserve that are subject to the Bank Secrecy Act.

The Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the National Credit Union Administration, and the Office of the Comptroller of the Currency (collectively, the federal banking agencies) 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 (SARs) and Other Anti-Money Laundering (AML) Considerations.

Financial institutions, including those supervised by the Federal Reserve1, 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 FAQs are intended to provide clarity to industry questions regarding certain SAR filing requirements and compliance processes. The FAQs have been issued as a result of discussions among law enforcement, regulators, and industry representatives through the Bank Secrecy Act Advisory Group. The FAQs do not alter existing BSA/AML legal or regulatory requirements, or establish new supervisory expectations.

Federal Reserve Banks are asked to distribute this letter to the supervised institutions in their districts and to appropriate supervisory staff. In addition, supervised organizations may send questions regarding the FAQs via the Board's public website.2

signed by
Michael Gibson
Director
Division of
Supervision and Regulation

Attachments:
Notes:
  1. The Federal Reserve supervises bank holding companies, which have a regulatory obligation to report suspicious activity under 12 CFR 225.4(f) (Regulation Y).  Accordingly, the SAR FAQs may be relevant in part to bank holding companies.  Return to text.
  2. See, http://www.federalreserve.gov/apps/contactus/feedback.aspx.  Return to text.
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Last Update: January 21, 2021