BSA Timeline
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| 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) |