Who files a SAR?

The Bank Secrecy Act and implementing rules require certain financial institutions to report specified suspicious transactions. The applicable rule depends on the institution type. This entry covers the bank rule in 31 CFR § 1020.320; other industries have their own rules and thresholds.

Bank reporting threshold and timing

Under the bank rule, a bank generally must file when a transaction involves or aggregates at least $5,000 and the bank knows, suspects, or has reason to suspect that the transaction meets the rule's criteria. The regulation includes additional conditions and exceptions, so the threshold alone does not decide whether a filing is required.

A bank generally files within 30 calendar days after initial detection of facts that may constitute a basis for a SAR. If no suspect is identified on the date of detection, the bank may take up to an additional 30 calendar days to identify a suspect, but the filing may not be delayed beyond 60 calendar days after initial detection. The rule also addresses situations requiring immediate notification to law enforcement.

FinCEN's SAR FAQs discuss continuing-activity reports. They describe a 90-day review and a 120-day filing interval as guidance for institutions that choose to file continuing SARs; those intervals should not be presented as a universal statutory deadline.

Confidentiality and records

The bank rule generally prohibits disclosing a SAR or information that would reveal its existence, subject to specified exceptions. A bank must retain a copy of the SAR and supporting documentation for five years from filing. Apply the rule for the institution and record at issue; do not treat a SAR as an ordinary customer communication.

Example

A bank's monitoring process flags a set of transactions for review. The bank investigates the available records and determines whether the facts meet its reporting rule. If it files a SAR, it keeps the report confidential, preserves supporting documentation, and follows the deadlines in the applicable regulation. A monitoring alert by itself is not a SAR and does not establish wrongdoing.

Related AML concepts

A SAR may relate to transaction monitoring, anti-money laundering (AML) and know your customer (KYC). These terms describe connected controls, but they are not interchangeable with the report itself.

Frequently asked questions

Is a SAR proof of a crime?

No. It reports suspicious activity under the applicable rule; it does not establish guilt or prove that a crime occurred.

What is the bank SAR filing deadline?

Generally 30 calendar days after initial detection. If no suspect is identified, the bank may take up to 60 days from initial detection, subject to the regulation's conditions.

Are continuing SARs due every 120 days?

FinCEN describes a 120-day interval in FAQ guidance for institutions that elect to file continuing-activity SARs. It is not a universal statutory deadline for every SAR.

Can a bank tell a customer that it filed a SAR?

The bank rule generally prohibits disclosure of a SAR or information that would reveal its existence, subject to specific exceptions.