FinCEN publishes new guidance clarifying that banks may share cross-border transaction and customer information to strengthen AML/CFT efforts while keeping SARs strictly confidential

The guidance emphasizes that financial institutions may voluntarily exchange underlying factual and transactional data with foreign counterparts, provided such sharing does not reveal the existence of a SAR. It underscores that this discretion must be exercised in light of each institution’s risk profile, legal obligations, and the need to protect sensitive information.