Bank Secrecy Act (BSA)

Compliance with the Bank Secrecy Act (BSA) is required for a broad range of financial institutions and related businesses in the U.S. This includes banks, credit unions, money service businesses (like money transmitters, check cashers, and prepaid card issuers), broker-dealers, casinos, card clubs, certain insurance providers, loan and mortgage companies, as well as fintech firms and crypto exchanges, which are facing increasing regulatory attention. These organizations must register with FinCEN and establish strong anti-money laundering (AML) programs.

BSA compliance means meeting the specific regulatory requirements of the Bank Secrecy Act, while AML compliance covers the broader set of policies and procedures for detecting and reporting suspicious financial activity. Together, BSA/AML compliance includes customer due diligence (CDD), enhanced due diligence (EDD), filing suspicious activity reports (SARs), submitting currency transaction reports (CTRs) for cash transactions over $10,000, recordkeeping, transaction monitoring, internal controls, independent audits, and employee training. These measures help institutions identify and respond to potential money laundering, fraud, or sanctions evasion.

The BSA Officer, also known as the Compliance Officer, is the person responsible for making sure an institution meets all BSA/AML requirements. Key duties include designing and managing the BSA/AML compliance program, overseeing transaction monitoring and investigations, reviewing and filing Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs), ensuring staff are trained on AML regulations, serving as the main contact for regulatory agencies like FinCEN or the OCC, and conducting regular risk assessments and internal audits. An effective BSA Officer helps the organization avoid penalties, protect its reputation, and remain compliant with federal regulations.