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
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
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
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
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

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)


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)