IRS Criminal Investigation has revealed that Bank Secrecy Act data plays a central role in nearly all of its financial crime investigations, with 94% of cases in fiscal year 2025 utilizing BSA filings. According to the agency, investigators conducted more than 3.9 million searches of BSA data during the fiscal year, underscoring the critical importance of financial reporting systems in building criminal cases against fraudsters, money launderers, and tax evaders.
CI Chief Guy Ficco stated that BSA data often provides the first indication that suspicious activity is occurring. These filings serve as essential components in identifying patterns, tracing financial trails, and constructing cases involving money laundering, cybercrimes, government program abuse, and narcotics trafficking, the agency reports.
Understanding Bank Secrecy Act Requirements
The Bank Secrecy Act was enacted in 1970 in response to concerns that organized crime and tax evaders were moving large sums of money through banks without creating a traceable investigative trail. The statute established the $10,000 reporting threshold for currency transactions that remains in effect today.
Additionally, the BSA underwent significant expansion during the 1980s through anti-money-laundering reforms and again following the September 11 attacks with the USA PATRIOT Act. The Financial Crimes Enforcement Network, known as FinCEN, currently administers the BSA and requires financial institutions to file reports, implement compliance programs, and conduct customer due diligence.
How BSA Data Supports Criminal Investigations
Modern financial crime investigations rely heavily on pattern recognition rather than dramatic informant tips or surprise discoveries. Suspicious Activity Reports, Currency Transaction Reports, and Forms 8300 provide the structured data that allows investigators to identify and connect patterns of illicit financial activity.
According to FinCEN’s Year-in-Review, approximately 432,000 registered filers participated in BSA reporting during fiscal year 2024. The actual number of filings reaches tens of millions across different report types, creating a comprehensive financial intelligence system.
Types of Financial Reports
Suspicious Activity Reports are filed by banks, credit unions, broker-dealers, and other financial institutions when they detect transactions that may involve legal violations or attempts to evade reporting requirements. FinCEN received approximately 4.7 million SARs in fiscal year 2024, averaging roughly 12,870 filings per day.
Meanwhile, Currency Transaction Reports are filed when a person conducts cash transactions exceeding $10,000 in a business day. Financial institutions filed about 20.5 million CTRs in fiscal year 2024, an average of approximately 56,160 filings per day, according to FinCEN data.
Furthermore, businesses must file Form 8300 when receiving more than $10,000 in cash in single or related transactions. In fiscal year 2024, businesses filed approximately 470,400 Forms 8300 reporting cash payments over $10,000, the agency indicated.
Effectiveness of the $10,000 Threshold
The $10,000 reporting threshold continues to generate debate among policymakers. If adjusted for inflation from 1970, the threshold would exceed $85,000 today, leading some to question whether it remains appropriate.
However, law enforcement agencies maintain that the threshold remains operationally effective. Most investigative CTR amounts cluster between $12,000 and $12,543, and nearly half of relevant investigations involve amounts under $20,000, suggesting the current threshold successfully captures suspicious activity.
In contrast, structuring—the practice of breaking transactions into smaller amounts to avoid reporting requirements—demonstrates why the threshold remains valuable. Ficco explained that criminals deliberately structure transactions tied to illicit activity to avoid detection, and CTRs provide concrete transactional data that often serves as evidence when proving criminal activity occurred.
Impact on Major Investigations
From fiscal year 2023 to fiscal year 2025, CI investigated 1,394 refund fraud cases involving alleged fraud totaling $2.9 billion. The agency reports that 93% of those cases had a BSA filing associated with the primary subject, with financial movements such as rapid government fund deposits and high-velocity withdrawals triggering SAR and CTR activity.
During the same period, CI opened 1,006 employment tax evasion cases with alleged fraud totaling $1.4 billion. Nearly two-thirds of those investigations had a BSA filing associated with the primary subject, according to agency data.
Additionally, BSA data supports prosecutions that result in high conviction rates and significant financial recoveries. From fiscal year 2023 through fiscal year 2025, CI cases using BSA filings achieved a 98% conviction rate, with average prison sentences of 42 months, asset forfeitures exceeding $450 million, and restitution for crime victims totaling nearly $500 million.
Interagency Collaboration and New Initiatives
The Federal Bureau of Investigation and Homeland Security Investigations also rely on SARs and CTRs to develop leads and support cases. The FBI reported that in fiscal year 2024, 32% of its active complex financial crime investigations were linked to SARs and CTRs.
CI leads or participates in SAR review teams across 94 federal judicial districts, where multiple law enforcement partners analyze BSA filings to identify actionable reports and assign leads. Between fiscal year 2023 and fiscal year 2025, these teams seized assets valued at $385.4 million, the agency reported.
In March 2025, CI announced CI-FIRST, a public-private partnership designed to modernize the agency’s work with financial institutions. The program provides strategic feedback on how BSA filings are used in tax and financial crime investigations and includes FinTAX crime alerts highlighting emerging fraud schemes.
The Optimizing Financial Records Requests initiative aims to streamline how CI issues legal process and how financial institutions respond, with the goal of standardizing request formats and reducing delays in obtaining financial records. Both initiatives are expected to continue evolving as CI works to enhance collaboration with the financial sector and improve investigative efficiency.
