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

Summary

On September 2, 2026, the Office of the Comptroller of the Currency, the Board of Governors of the Federal Reserve System, the Federal Deposit Insurance Corporation, the Financial Crimes Enforcement Network (FinCEN), and the National Credit Union Administration issued a statement to clarify confidentiality requirements related to Suspicious Activity Reports (SAR), particularly when banks communicate with their customers regarding potentially fraudulent transactions.

Highlights

The joint statement highlights that

• the Bank Secrecy Act prohibits the disclosure of a SAR or information that would reveal the existence of a SAR.
• the SAR confidentiality requirements do not prohibit banks from communicating with an individual when such communication involves the underlying facts, transactions, and documents upon which a SAR is based.
• a bank should consider customer communication on a case-by-case basis and take precautions when discussing information that could reveal the existence of a SAR.

In addition, the joint statement provides a non-exhaustive list of communications that would not typically reveal the existence of a SAR.

Further Information

Please contact the Compliance and Operational Risk Division, Office of the Chief National Bank Examiner, at (202) 649-6550.

James M. Gallagher
Senior Deputy Comptroller and Chief National Bank Examiner

Related Link

• Joint Statement on Suspicious Activity Report Confidentiality Considerations Regarding Communications with Customers (PDF)