What is BSA?

Bank Secrecy Act

Why BSA Matters

The BSA forms the backbone of the US AML regulatory framework and has been significantly expanded over the decades — notably by the USA PATRIOT Act (2001) and the Anti-Money Laundering Act of 2020. It applies to a broad range of financial institutions, including banks, credit unions, broker-dealers, money services businesses (MSBs), casinos, and — crucially for the digital asset industry — cryptocurrency exchanges. The BSA's reach extends beyond traditional finance, making it a critical compliance consideration for any business handling financial transactions in or connected to the United States.

Regulatory Implications

The BSA imposes several key obligations on covered financial institutions:

• Currency Transaction Reports (CTRs): Financial institutions must file CTRs for cash transactions exceeding $10,000 in a single business day, per customer.
• Suspicious Activity Reports (SARs): Institutions must file SARs when they detect transactions that may involve money laundering, terrorist financing, or other suspicious activity — typically for transactions of $5,000 or more.
• Customer Identification Program (CIP): Institutions must verify the identity of customers opening accounts, collecting name, date of birth, address, and identification number.
• AML compliance program: Every covered institution must maintain a written AML program that includes internal policies, a designated compliance officer, employee training, and independent testing.
• Beneficial ownership: Under the Corporate Transparency Act (part of the AML Act of 2020), companies must report beneficial ownership information to FinCEN.

How BSA Relates to Compliance Monitoring

BSA regulations are enforced by FinCEN, federal banking regulators, and state regulators. Rules and guidance evolve through regulatory notices, enforcement actions, advisories, and rulemaking proceedings. The AML Act of 2020 introduced significant changes that are still being implemented through new FinCEN rules. RegPulse monitors all BSA-related developments including FinCEN advisories, proposed rules, final rules, and enforcement actions.