BSABank Secrecy Act
Enacted in 1970 as the Currency and Foreign Transactions Reporting Act, the BSA is the foundation of US AML law. It requires financial institutions to keep records, report cash transactions over $10,000 in a day through Currency Transaction Reports (CTRs), and file Suspicious Activity Reports (SARs). FinCEN administers the BSA on behalf of the US Treasury.
Why it matters
The BSA applies to banks, credit unions, money services businesses, broker-dealers, casinos and other covered businesses. Each must run a written AML program with internal controls, a designated compliance officer, ongoing training and independent testing, plus customer identification and customer due diligence. Examiners from the federal banking agencies, and from state regulators, test these programs against the FFIEC BSA/AML Examination Manual.
The law has been expanded several times. The USA PATRIOT Act of 2001 added stronger customer identification, correspondent banking and information-sharing rules. The Anti-Money Laundering Act of 2020 modernized the framework, called for risk-based and effective programs, expanded whistleblower protections and included the Corporate Transparency Act, whose beneficial ownership reporting FinCEN narrowed to foreign companies in March 2025.
In practice, BSA compliance depends on transaction monitoring that surfaces unusual activity quickly enough to investigate and file a SAR within the regulatory deadline, generally 30 days after initial detection.
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