FinCEN SAR and CTR Filing

SAR vs CTR at a Glance

Suspicious Activity Reports (SARs)

A SAR is required when a transaction conducted or attempted by, at or through your institution meets the dollar threshold and you know, suspect or have reason to suspect it involves funds from illegal activity, is designed to evade BSA requirements, has no business or apparent lawful purpose, or uses your institution to facilitate criminal activity.

Thresholds

• Banks: transactions that involve or aggregate at least $5,000 (31 CFR 1020.320)
• Money services businesses: transactions that involve or aggregate at least $2,000. Issuers of money orders or traveler's checks reviewing clearance records report at $5,000 (31 CFR 1022.320)

The 30-day deadline

A SAR is due no later than 30 calendar days after the date you first detect facts that may constitute a basis for filing. Banks that have not identified a suspect may take up to 30 more days to identify one, but never more than 60 calendar days from initial detection. The MSB rule has no equivalent extension. For violations that need immediate attention, such as ongoing money laundering schemes, notify law enforcement by phone as well as filing.

Continuing activity

FinCEN's October 2025 FAQs, issued with the federal banking agencies, clarify that institutions are not required to run a separate review of a customer or account after filing a SAR, and that continuing activity does not have to be reported on a fixed 90-day cycle. Institutions may file further SARs as appropriate within the applicable timelines. The same FAQs confirm there is no BSA requirement to document a decision not to file.

Confidentiality and records

Keep a copy of each SAR and its supporting documentation for five years from the filing date. Supporting documentation is deemed filed with the SAR. SARs are confidential: do not disclose a SAR, or information that would reveal one exists, except as the regulations permit.

Currency Transaction Reports (CTRs)

Financial institutions other than casinos must file a CTR for each deposit, withdrawal, exchange of currency or other payment or transfer involving a transaction in currency of more than $10,000 (31 CFR 1010.311). Casinos have their own currency transaction reporting rule under 31 CFR Part 1021.

Aggregation by business day

Multiple currency transactions count as a single transaction if you know they are by or on behalf of the same person and total more than $10,000 in cash in, or in cash out, during one business day. Cash in and cash out are totalled separately, not netted against each other. Deposits made at night, over a weekend or on a holiday count as received on the next business day (31 CFR 1010.313).

The 15-day deadline

File the CTR within 15 days following the day of the reportable transaction, and keep a copy for five years from the date of the report (31 CFR 1010.306).

FinCEN Filing in Quantoflow

SAR filing will run on the same platform teams already use for FINTRAC reporting. Alerts from Quantoflow Monitoring escalate into Quantoflow Cases, where investigators build the evidence and draft the narrative, and the finished report is validated before it is submitted, as it is in Quantoflow Report. Teams that report in both countries will keep one platform and one audit trail on both sides of the border.