SARs filings are hitting record highs; however, more filings do not mean better intelligence. And now, agentic AI is poised to increase filings dramatically, making it essential for the financial crime community to focus on the effectiveness of SARs before the system becomes overwhelmed
Key insights:
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SAR volume is significantly underreported — Continuing and amended filings add approximately 20% to the official count yet remain invisible in trend analyses.
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Filing activity is highly concentrated — A few large financial institutions dominate SARs volume, meaning trends reflect their practices more than systemic changes.
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Agentic AI will drive a surge in SARs — Agentic AI risks increased noise over actionable intelligence, without addressing the unresolved question of whether current filings yield meaningful law enforcement outcomes.
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The Suspicious Activity Reports (SAR) that financial institutions file with the U.S. Treasury Department’s Financial Crimes Enforcement Network (FinCEN) provide valuable insight, although they may not offer a comprehensive picture.
Prior to meaningful discussions regarding the future of SARs, it is essential for the financial crime community to clarify what is being measured. In 2025, for example, SAR filings reached a record high of more than 4.1 million, representing an almost 8% increase compared to the total number of SARs filed in 2024.
Every figure FinCEN has published reflects original SARs only. Continuing activity SARs, which represent roughly 15% of all filings, are submitted under the original Bank Secrecy Act (BSA) identification number and never appear as new filings. Corrected and amended SARs add another 5% on top of that. This makes the real volume of SARs activity approximately 20% higher than what is reported.
The average community bank files fewer than one SAR a week, while the largest institutions file more than 500 a day.
Recent FinCEN guidance giving financial institutions more flexibility around continuing activity SARs sounds significant on paper, but as former Wells Fargo BSA/AML chief Jim Richards points out: “It won’t change the reported numbers — because those filings were never counted to begin with.” Financial crime professionals need to keep that gap in mind every time a trend line gets cited.
2025 was steady, not spectacular
There were roughly 300,000 SARs filed every single month of 2025, and the most notable thing is that nothing notable happened. That is likely a first on the volume side and worth acknowledging, but beyond that milestone the year did not hand financial crime professionals anything noteworthy. In a space that has dealt with pandemic distortions, crypto chaos, and fraud spikes that seemed to come out of nowhere, steady volume and predictable patterns are a little surprising. A quiet data set, however, is not the same as a quiet landscape, and financial crime professionals who are reading stability as stagnation may find themselves flat-footed when the numbers start moving again.
For example, one of the most underleveraged insights in the SARs space is just how concentrated filing activity really is. The numbers are stark: The top four banks file more SARs in a single day than 80% of the rest of the banks file in 10 years, according to 2019 data from a FinCEN notice published on May 26, 2020 (85 FR 31598).
The average community bank files fewer than one SAR a week, while the largest institutions file more than 500 a day. “50 a year versus 500 a day,” notes Wells Fargo’s Richards, adding that such asymmetry has real implications for how the financial industry interprets trends. Meaningful movement in SARs data, up or down, is almost entirely dependent on what a handful of mega-institutions decide to do.
Not surprisingly, money services businesses (MSBs) are the second largest filing category, and virtual currency exchanges are almost certainly driving recent growth there, even if outdated category definitions make that difficult to confirm directly. Credit unions round out the top three.
The filing philosophy hasn’t changed and shouldn’t
Regulatory noise occasionally suggests that institutions should be more selective about what they file. However, compliance and legal reality have not shifted. No institution has ever faced serious consequences for filing too many SARs, and the cases that result in enforcement actions, reputational damage, and regulatory scrutiny are consistently about missed filings or late ones.
“You’re not going to get in trouble from filing too much,” Richards says. “Nobody ever has, and I doubt if anyone ever will.” For financial crime professionals, the calculus remains exactly what it has always been — when in doubt, file. That posture isn’t going to change, and frankly it shouldn’t.
Yet, here is where the SARs space gets genuinely interesting. Agentic AI use in SARs filings — systems in which multiple AI agents work through a case from screening to decision to documentation — is beginning to move from concept to deployment. The impact on filing volume likely will be significant.
The risk is a system flooded with AI-generated SARs of variable quality, creating more noise for law enforcement to sort through rather than sharper intelligence to act upon.
Whereas a small team today might work through a handful of cases a week, AI-assisted workflows could push that into the dozens. Multiply that across institutions already inclined to file rather than miss something, and the result is a coming surge in SARs volume that could play out over the next two to four years.
“Agentic AI has the potential to be a game changer on how we do our work,” Richards explains. “But I believe it’ll guarantee that there will be more SARs filed and not necessarily better and fewer SARs filed.” Indeed, the critical point for the financial crime community to internalize is exactly that.
The risk is a system flooded with AI-generated SARs of variable quality, creating more noise for law enforcement to sort through rather than sharper intelligence to act upon. Once the largest institutions adopt agentic AI as a best practice, others will follow quickly, and regulators will likely be several steps behind.
The value question can’t wait
The marijuana SARs guidance has been in place since 2014. Yet after 12 years of filings, the financial crime community still lacks a clear public accounting of whether that data has produced actionable law enforcement outcomes.
So, the question Richards is asking is one the entire industry should be asking: “Has anybody asked law enforcement?”
This question reflects a larger challenge that the industry needs to confront more aggressively, especially as AI technology is set to dramatically increase filing volume across the board. Increasing the volume without improving how the information is used does not represent progress. If SARs are not generating real investigative value, the solution is not to file more of them faster — instead, the pipeline should be fixed before it grows any bigger.
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