FinCEN.gov


1970	Large currency deposits of illicit profits	Bank Secrecy Act (BSA) enacted
1974	Constitutionality of Bank Secrecy Act questioned	U.S. Supreme Court holds BSA to be constitutional
1986	Law Enforcement looks for new weapons to combat drug trafficking	Enact Money Laundering Control Act
1990	Insufficient intelligence analysis and resources to support financial investigations	Create Financial Crimes Enforcement Network (FinCEN)
1992	Law enforcement needs more information on suspicious transactions to support financial investigations	Enact Annunzio-Wylie Money Laundering Suppression Act -Suspicious activity reporting required
1994	Law enforcement focuses on criminal abuse of MSBs CTR exemption process is a burden for financial community	Enact Money Laundering Suppression Act - MSB registration CTR filing required
1994	Improve cooperation and coordination between regulatory,financial and law enforcement communities	Merge Treasury’s Office of Financial Enforcement with FinCEN - FinCEN’s Mission expanded to include regulatory authority
1998	Improve coordination of federal, state and local efforts and resources to combat financial crimes	Enact Money Laundering & Financial Crimes Strategy Act - National Money Laundering strategy established - HIFCA system created
2000	Law enforcement needs more information on money transmitters, and issuers, sellers and redeemers of money	MSBs required to file suspicious Activity Reports (SARs)
2001	Terrorists attack the World Trade Center & Pentagon; President announces Financial War on Terror at FinCEN	Enact PATRIOT Act - Information Sharing - Registration requirements for underground money transmitters
2002	Institutions are front line against money laundering and terrorist financing	Most financial institutions receive a new or amended AML Program requirement
2002	Law enforcement needs more information on casinos	Casinos required to file SARs
2002	Importance of information sharing recognized	Sharing between institutions is protected, and between institutions and government is required
2002	Foreign shell banks recognized as threat	Termination of accounts for shell banks and certification by foreign correspondents required
2002	Financial institutions seek to expedite reporting process, reduce costs in complying with BSA requirements	PATRIOT Act Communications System (PACS) launched - Financial institutions can file BSA reports electronically
2002	PATRIOT Act expands regulatory definition of "financial institution"	Brokers and dealers in securities must file SARs
2003	Need to protect more MSBs from financial crimes	Currency Dealers and Exchangers required to file SARs
2003	Identification requirement strengthened	Customer Identification Programs required for most financial institutions
2003	Need to protect casinos from money launderers	Casinos and card clubs required to file SARs - includes those operated on tribal lands
2003	FinCEN expands regulatory definition of "financial institution"	Futures commission merchants, introducing brokers in commodities required to report suspicious transactions
2004	U.S. financial system needs additional protection from risks of financial crime posed by foreign agents	MSBs receive guidance for dealing with foreign agents and foreign counterparts
2005	Certain account services need greater scrutiny	Due diligence requirements for private banking and foreign correspondent
2005	Improve management of BSA data, from filing and storage to retrieval and analysis	PACS renamed as BSA E-Filing - 25% of BSA filings and 40% of SARs are e-filed as of March 2005
2005	Improve collaboration and information sharing between federal and state agencies	FinCEN, 29 states sign Memoranda of Under- standing (MOU) -established information sharing agreements
2005	Jewelry industry needs protection against financial crime	Jewelers, dealers in precious metals and stones required to establish anti-money laundering (AML) programs
2005	Increased international effort to combat money laundering, terrorist financing	Egmont Group of financial intelligence units exceeds 100-member mark
2005	Need to ensure consistent application of BSA to all banking organizations	Federal banking agencies release BSA/AML Examination Manual
2005	Need to protect insurance industry from financial crimes	Certain insurance companies required to establish AML programs, file SARs
2006	Need to protect mutual funds from financial crimes	Mutual funds required to file SARs
2007	Certain account services need greater scrutiny	Enhanced due diligence is required for certain foreign correspondent banks
2009	Need to simplify requirements for depository institutions to exempt their eligible customers from currency transaction reporting	Final Rule on CTR Exemptions takes effect (Jan. 5, 2009)
2011	Need to enhance efficiency and effectiveness	Transfer of FinCEN’s regulations to 31 CFR Chapter X
2011	MSB rules amended to establish a more comprehensive regulatory approach for prepaid access	FinCEN issues prepaid access Final Rule (Effective Date: September 27, 2011; Compliance Date: January 29, 2012)
2012	Need to combat fraud in the non-bank residential mortgage sector	Final Rule defines non-bank residential mortgage lenders and originators (RMLOs) as loan or finance companies. RMLOs required to establish AML programs and file SARs (Effective Date: April 16, 2012; Compliance Date: August 13, 2012)
2014	Law enforcement and regulators need more complete and timely information on suspected mortgage fraud and money laundering	Housing GSEs required to develop AML programs and file SARs (Effective Date: April 28, 2014; Compliance Date: August 25, 2014)
2016	Need to clarify and strengthen customer due diligence requirements for banks; brokers or dealers in securities; mutual funds; and futures commission merchants and introducing brokers in commodities	Final Rule contains explicit customer due diligence requirements and includes a new requirement to identify and verify the identity of beneficial owners of legal entity customers, subject to certain exclusions and exemptions (Effective Date: July 11, 2016; Compliance Date: May 11, 2018)

BSA Timeline