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

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

SUBJECT:

Joint Statement on Suspicious Activity Report Confidentiality Considerations Regarding Communications with Customers

The Board of Governors of the Federal Reserve System (Board), the Federal Deposit Insurance Corporation (FDIC), the National Credit Union Administration, the Office of the Comptroller of the Currency (OCC), and the Financial Crimes Enforcement Network (collectively, the agencies) are issuing a joint statement to clarify confidentiality requirements related to Suspicious Activity Reports (SARs), particularly when banks communicate with their customers regarding potentially fraudulent transactions, other suspicious activity (e.g., payment fraud, including check fraud), or account closures. This statement does not alter existing BSA legal or regulatory requirements or establish new supervisory expectations.

This action taken by the agencies reflects industry feedback received from the request for information on Potential Actions to Address Payments Fraud issued by the Board, FDIC, and OCC in June 2025.¹ Commenters specifically requested clarification on how banks can ensure compliance with SAR confidentiality requirements and provide customers with transparent and timely communication as part of the bank's fraud investigation, which may result in one or more SAR filings and potential closure of a customer's account.

SAR confidentiality is a statutory and regulatory requirement that helps to ensure that SAR information is disclosed only for appropriate purposes. The BSA and its implementing regulations do not prohibit banks from communicating with a customer or other person who may be the subject of a SAR about potentially fraudulent or other suspicious transactions involving the customer's account or notifying the customer of the bank's intention to close the account for potentially fraudulent or other suspicious activity, so long as that communication does not reveal the existence of a SAR.

Reserve Banks are asked to distribute this SR letter to supervised domestic and foreign financial institutions that are subject to the BSA, as well as to supervisory and examination staff. In addition, questions may be sent via the Board's public website.²

signed by
Randall D. Guynn
Director
Division of
Supervision and Regulation

Attachments: