Unknown Sponsor Bank
On January 19, 2021, FinCEN along with other federal banking agencies published FAQs providing clarification on Suspicious Activity Report (SAR) filing requirements and risk-based compliance approaches. The guidance addressed financial institutions that handle high-risk clients, including money services businesses (MSBs) often onboarded through bank-fintech partnership arrangements. While the FAQs did not impose new regulatory obligations, they reinforced expectations around BSA/AML compliance in the context of third-party and partner-driven banking relationships. The guidance is relevant to BaaS providers and sponsor banks that facilitate fintech access to the banking system for payments and money transmission services.
Verified from source: On January 19, 2021, FinCEN along with OCC, FDIC, Federal Reserve, and NCUA jointly published FAQs regarding Suspicious Activity Reporting and other AML considerations, clarifying SAR requirements and emphasizing risk-based approaches for financial institutions without changing existing legal obligations.
- Sponsor banks and BaaS providers must ensure SAR filing practices align with clarified FinCEN expectations for partner-originated activity
- Reinforces risk-based approach expectations for banks serving high-risk fintech and MSB clients
- May signal increased supervisory attention to BSA/AML practices in bank-fintech partnership models