FinCEN’s recordkeeping and reporting requirements help to detect and deter all types of illicit activity, including money laundering, the financing of terrorist activity, and many types of fraud. Reports filed pursuant to FinCEN’s regulations implementing the BSA create a financial trail that law enforcement and intelligence agencies use to track criminals and terrorist networks, their activities, and their assets. Recordkeeping and reporting requirements work hand-in-hand with FinCEN’s AML program requirements, which help financial institutions protect themselves from criminal abuse by
identifying and mitigating the risks inherent in their operations. Financial institutions filed approximately 17.1 million reports pursuant to these regulatory requirements in fiscal year 2011. Financial industry sectors subject to FinCEN’s reporting requirements include – but are not limited to – depository institutions (e.g., banks, credit unions, and thrifts); broker-dealers in securities; mutual funds; futures commission merchants and introducing brokers in commodities; money services businesses (currency dealers and exchangers; check cashers; and the U.S. Postal Service); casinos and card clubs; insurance companies; and dealers in precious metals, precious stones, or jewels.
A variety of reports are required under FinCEN’s regulations, but the majority of reports filed are of two types:
▪▪ Currency Transaction Reports (CTRs) are filed in connection with cash deposits, withdrawals, exchanges of currency, or other payments or transfers by, through, or to a financial institution involving a transaction (or multiple transactions by or on behalf of the same person) in currency exceeding $10,000. Currency transaction reporting requirements are a key impediment to criminal attempts to legitimize the proceeds of crime. Based on preliminary data, about 14.8 million CTRs were filed in fiscal year 2011, compared with about 14 million in fiscal year 2010.
▪▪ Suspicious Activity Reports (SARs) are filed in connection with transactions that financial institutions know, suspect, or have reason to suspect may be related to illicit activity. These reports are especially valuable to law enforcement because they reflect activity considered problematic or unusual by depository institutions, casinos, MSBs, securities broker-dealers, mutual funds, futures commission merchants, introducing brokers in commodities, and insurance companies. SARs contain sensitive information and, consequently, may be disclosed and disseminated only under strict guidelines. Unauthorized disclosure of SARs may lead to criminal penalties. About 1.4 million SARs were filed in fiscal year 2011, compared with 1.3 million filed in fiscal year 2010.
Bank Secrecy Act Filings by Type, Fiscal Years 2009 – 2011
| Type of Form | FY 2009 | FY 2010 | FY 2011 |
| Currency Transaction Report (all types) | 14,909,716 | 14,065,871 | 14,826,316 |
| Suspicious Activity Report (for all covered industries) | 1,321,848 | 1,319,984 | 1,446,273 |
| Report of Foreign Bank and Financial Accounts | 276,386 | 594,488 | 618,134 |
| Registration of Money Services Business4 | 19,234 | 20,302 | 20,315 |
| Designation of Exempt Person5 | 32,117 | 22,990 | 18,616 |
| Report of Cash Payments Over $10,000 Received in a Trade or Business (Form 8300) | 180,801 | 174,023 | 194,366 |
| Total6 | 16,740,102 | 16,197,658 | 17,124,020 |
Detailed report link: here