From Thresholds to Thrust: The Real Meaning Behind FinCEN’s New SAR FAQs

If your compliance team still treats the $10,000 mark as the only trigger for filing a SAR, it’s time for a rethink. On October 9, 2025, Financial Crimes Enforcement Network (FinCEN), along with the federal banking agencies, released updated FAQs clarifying what really triggers a Suspicious Activity Report (SAR) under the Bank Secrecy Act.

In short: a transaction at or near the $10,000 Currency Transaction Report (CTR) threshold does not automatically require a SAR. Instead, SARs must be filed when the institution knows, suspects, or has reason to suspect that the activity is designed to evade reporting rules—or otherwise meets the criteria for suspicious activity.

Why does this matter?

It’s a big deal because alerts and filings have been piling up for years—many triggered solely because transactions hit a numeric threshold rather than showing any meaningful suspicion. That’s especially true for fintechs, MSBs and smaller banks managing complex customer behaviors.

Under the new FAQs, the emphasis shifts: from “did it hit the number?” to “is there something about why it happened that makes it suspicious?” It’s less box-checking and more detective work.

What many institutions still struggle with

At High Risk Education, we hear this often:

• Threshold trigger logic only. The compliance system fires because “$10,000+,” but no deeper question is asked: Is this unusual, does it diverge from the customer’s profile, or is there evidence of evasion?
• Decisions “not to file” are poorly documented. FinCEN clarified you’re not required to document every decision not to file a SAR if you follow risk-based policies, but institutions still need credible processes.
• Rigid, one-size-fits-all 90-day reviews. The old assumption: after a SAR is filed you must review every 90 days. The new guidance says that’s optional unless risk triggers demand it.
• False positive overload. When the alert logic is too broad, teams get buried in noise. That means real threats get buried under mountains of irrelevant alerts.

How High Risk Education’s courses can help you adapt

At HRE we’ve pivoted our training to meet the changing expectations—and help you get ahead:

• How to Write and File Effective SARs for Stronger AML Reporting – A foundational course that shows you when the filing obligation truly arises, and how to articulate it.
• How to Write Advanced SARs and Manage Complex AML Investigations – For when things are more complex: crypto schemes, structuring patterns, trade-based money laundering.
• How to Use Section 314(b) for Smarter Financial Crime Collaboration – Because SARs alone don’t always crack the network; coordinated intelligence sharing matters.

These courses help you rewire your team’s mindset: from quantity of filings to quality, from “did it hit the number?” to “why does it matter?” From reactive to risk-based compliance.

Practical next steps

Here’s what you can do right now:

• Revise your alert logic. Remove rules that fire simply because a deposit hits $10,000. Add context: customer profile, channel behavior, history, geography.
• Review your “no-file” process. Document when you decide not to file a SAR but make sure the decision is supported by clear, written policy and reasoning.
• Rethink regular “every 90 days” reviews. Unless the risk justifies it, don’t force a schedule just for the sake of it. Let your risk-based controls drive timing.
• Train your team in narrative logic. The number alone rarely tells the story. A strong narrative shows investigation, decision-making, and risk awareness.
• Link SAR work with broader collaboration. If you’re working with fintechs, MSBs or partners, consider how 314(b) information-sharing or vendor oversight can support your program (we cover this in our 314(b) course).

The takeaway

FinCEN’s FAQs don’t change the law, they clarify how to apply it. They invite you to move from threshold-driven checklists to meaningful risk-based decisions.

That’s good news. Because growth and change are inevitable—new products, channels, fintech partnerships. But compliance doesn’t have to bog you down. With the right mindset, the right training, and the right narrative, compliance can become a growth enabler instead of a roadblock.

At HRE, we’re here to help you build that foundation, not just for today, but for a high-risk world that’s always changing. Visit us at highriskeducation.com