In this edition, we break down two major global regulatory updates shaping compliance strategy for 2025 and beyond from FinCEN’s new SAR filing FAQs in the U.S. to the formal launch of the European Anti-Money Laundering Authority (AMLA).

These changes signal one clear trend: regulators are tightening expectations on documentation, cross-border coordination, and accountability.

U.S. Update – FinCEN Issues New SAR Filing Guidance

The Financial Crimes Enforcement Network (FinCEN) and U.S. banking regulators issued updated Suspicious Activity Report (SAR) FAQs, clarifying how institutions should apply a risk-based approach and document their decisions.

Key Changes:

• Clearer guidance on when and how to file continuing SARs for ongoing suspicious activity.
• Expectations for documentation supporting “why we filed” and “why we didn’t file.”
• Reinforcement of risk-based programs, moving away from formulaic thresholds.

Impact: Firms must revisit their SAR decision workflows, ensure narrative quality, and maintain audit-ready documentation for regulatory review.

🇪🇺 EU Update – AMLA Officially Operational

The European Anti-Money Laundering Authority (AMLA) became operational under Regulation (EU) 2024/1620, ushering in a new unified AML/CFT supervision model across the EU.

What’s New

• Single AML Rulebook: Harmonises divergent national AML laws into one framework.
• Direct supervision: AMLA will oversee high-risk entities (including crypto & cross-border firms).
• Wider scope: Extends AML obligations to non-financial entities such as real-estate brokers, lawyers, and dealers in high-value goods.

Impact: Firms must align local controls with a pan-EU model particularly around risk classification, due diligence consistency, and suspicious activity reporting.

Expert Insight: The Bigger Picture

Both updates push compliance toward a smarter, data-driven, and well-documented model:

• In the U.S., FinCEN is asking why you filed, not just that you filed.
• In the EU, AMLA is removing national fragmentation to enforce consistency.

Bottom line: Compliance programs must now be globally connected, well-documented, and auditable in real-time.

What Firms Should Do Next

• Revisit SAR documentation standards – include clear reasoning and escalation logs.
• Align multi-jurisdiction frameworks – map overlaps between U.S. SAR rules and EU AMLA requirements.
• Upgrade training – ensure investigators understand how PF, crypto, and sanctions risks tie into SAR decisions.
• Audit data lineage – regulators expect traceability from red-flag trigger to decision rationale.