The Bank Secrecy Act (BSA), enacted in 1970, is the primary US anti-money laundering law requiring financial institutions to assist government agencies in detecting and preventing financial crimes.
Core Reporting Requirements
| Report | Trigger | Threshold |
|---|---|---|
| CTR (Currency Transaction Report) | Cash transactions | >$10,000 |
| SAR (Suspicious Activity Report) | Suspected illegal activity | >$5,000 (or any amount if terrorism suspected) |
Key BSA Provisions
- Recordkeeping: Maintain records of transactions and customer information
- Reporting: File CTRs and SARs with FinCEN
- Customer Identification: Verify customer identity at account opening
- AML Program: Maintain policies, procedures, and controls
BSA Expansion Over Time
| Year | Legislation | Added Requirements |
|---|---|---|
| 1970 | Bank Secrecy Act | Original CTR reporting |
| 2001 | USA PATRIOT Act | CIP, enhanced AML programs |
| 2016 | FinCEN CDD Rule | Beneficial ownership identification |
| 2021 | Corporate Transparency Act | BOI reporting to FinCEN |
BSA and KYB
The BSA requires financial institutions to know their business customers—driving KYB requirements. The CDD Rule specifically mandates identifying beneficial owners of legal entity customers.
FinCEN administers and enforces BSA compliance.