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Overview

Mission Statement

To enhance U.S. national security, deter and detect criminal activity, and safeguard financial 

systems from abuse by promoting transparency in the U.S. and international financial systems.

Program Summary by Budget Activity

Dollars in Thousands

Appropriation FY 2010 FY 2011 FY 2012 FY 2010 to FY 2012

Enacted Annualized

CR Level

Request $ Change % Change

 BSA Administration and Analysis $101,694 $101,694 $84,297 ($17,397) (17.1%)

 Regulatory Support Programs $9,316 $9,316 $0 ($9,316) (100.0%)

Total Appropriated Resources $111,010 $111,010 $84,297 ($26,713) (24.1%)

Transfers $0 $0 $30,000 $30,000 -

Total Program Operating Level $111,010 $111,010 $114,297 $3,287 3.0%

Total FTE 331 327 304 (27) (8.2%)

In FY 2012, the Regulatory Support Program budget activity is merged into the BSA Administration and Analysis budget 

activity.

FY 2012 Priorities

The following priorities support the Presidential goal of encouraging economic growth by 

safeguarding the financial systems from abuse and promoting transparency in the U.S. and 

international financial systems. 

• Implement the BSA IT Modernization Program, using funds transferred from the 

Treasury Forfeiture Fund (see Administrative Provisions Sec. 125); 

• Lead efforts to coordinate federal, state, and local efforts to combat fraud; 

• Enhance the BSA regulatory compliance and enforcement strategy based on risks 

informed by analysis and law enforcement; and 

• Engage with priority countries and international bodies to strengthen mechanisms for 

global information exchange. 
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Table of Contents

Overview ........................................................................................................................................ 1

Mission Statement....................................................................................................................... 1

Program Summary by Budget Activity....................................................................................... 1

Section 1 – Purpose ....................................................................................................................... 2

1A – Description of Bureau Vision and Priorities...................................................................... 2

1B – Program History and Future Outlook ................................................................................. 2

Section 2 – Budget Adjustments and Appropriation Language............................................... 7

2.1 – Budget Adjustments Table................................................................................................. 7

2A – Budget Increases and Decreases Description..................................................................... 7

2.2 – Operating Levels Table .................................................................................................... 10

2.3 – Appropriations Detail Table............................................................................................. 11

2B – Appropriations Language and Explanation of Changes................................................... 11

2C – Legislative Proposals........................................................................................................ 11

Section 3 – Budget and Performance Plan ............................................................................... 13

3.1 – Budget by Strategic Outcome .......................................................................................... 13

3.2.1 BSA Administration and Analysis Budget and Performance Plan .................................. 14

3.2.2 Regulatory Support Programs Budget and Performance Plan ......................................... 16

Section 4 – Supporting Materials .............................................................................................. 17

4A – Human Capital Strategy Description................................................................................ 17

4.1 – Summary of IT Resources Table...................................................................................... 21

4B – Information Technology Strategy..................................................................................... 22
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Section 1 – Purpose

1A – Description of Bureau Vision and Priorities

The Financial Crimes Enforcement Network (FinCEN), a Treasury Department bureau reporting 

to the Under Secretary of the Office of Terrorism and Financial Intelligence, plays a key role in 

supporting the Department’s strategic goal to prevent terrorism and promote the nation’s security 

through strengthened international financial systems. This role includes ensuring safer and more 

transparent U.S. and international financial systems through the administration of the Bank 

Secrecy Act (BSA).

The BSA requires financial institutions to file reports and maintain records on certain types of 

financial activity and to establish appropriate internal controls to guard against financial fraud, 

money laundering, terrorist financing, and other types of illicit finance. These reports and 

records have a high degree of usefulness in criminal, tax, and regulatory matters. Documents 

filed by businesses pursuant to the BSA requirements are heavily used by law enforcement 

agencies, both domestically and internationally, to identify, detect and deter financial fraud and 

money laundering, whether it is in furtherance of a criminal enterprise, terrorism, tax evasion or 

other unlawful activity. Acts of fraud and acts of money laundering are interconnected: the 

financial gain of the fraudulent activity ultimately needs to be integrated into the financial 

system. Money laundering is often a malignant and pernicious product of fraud. FinCEN also 

serves as the nation’s financial intelligence unit (FIU). An FIU serves as a national center to 

collect, analyze, disseminate, and exchange information pursuant to a country’s anti-money 

laundering/counter-terrorist financing (AML/CFT) legislation and regulations. This includes 

information about suspicious or unusual financial activity reported by the financial sector. FIUs 

have specific authority to share lead information with their foreign counterparts to combat crossborder financial crime. 

FinCEN’s activities and efforts are developed in coordination with federal, state, and 

international partners. These bureau efforts are linked to the following strategic goals:

• Financial systems resistant to abuse by money launders, terrorists, and their financial 

supporters, and other perpetrators of financial crime;

• Detection and deterrence of money laundering, terrorism financing, and other illicit 

activity; and 

• Efficient management, safeguarding, and use of BSA information. 

The total resources required to support FinCEN for FY 2012 are $117,297,000 including 

$84,297,000 for direct appropriation, $3,000,000 from offsetting collections and $30,000,000 

transferred from the Treasury Forfeiture Fund (see Administrative Provisions Sec. 125) to continue 

development and maintenance of the BSA Information Technology (IT) modernization program. 

1B – Program History and Future Outlook

FinCEN fulfills its mission, goals and priorities by: administering the BSA; supporting law 

enforcement, intelligence, and regulatory agencies through sharing and analysis of financial 

intelligence; enhancing financial anti-fraud efforts; international anti-money laundering and 
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counter terrorist financing efforts and cooperation; and networking people, entities, ideas, and 

information. 

In the regulatory area, FinCEN’s policy efforts focus on efficient and effective administration of 

the BSA. This includes improving the consistency in the application of BSA regulations to 

regulated financial institutions, providing guidance regarding regulatory expectations, 

conducting studies to provide feedback to stakeholders, and initiating enforcement actions when 

appropriate.

In FY 2010, FinCEN:

• Continued an extensive financial institution outreach initiative, focusing in FY 2010 on 

outreach to small depository institutions, such as community banks and credit unions. 

FinCEN completed this outreach through visits to individual institutions and participation 

in several “town hall” events for larger groups. Direct financial institution outreach 

enables FinCEN to carry out its mission as BSA administrator in the most efficient and 

effective manner possible and enhances FinCEN’s understanding of the operations of and 

challenges facing the institutions it regulates;

• Enhanced collaboration with law enforcement to identify sources of lead information and 

is developing analysis criteria to more effectively leverage BSA data to identify potential 

non-compliant institutions. This strategy should enable FinCEN to become even more 

proactive in identifying and taking action against non-compliant institutions as 

warranted. In addition, FinCEN continues to work closely with the Department of Justice 

to coordinate investigations in order to proceed concurrently on both civil and criminal 

actions, where appropriate;

• Continued to participate in the U.S. Government’s coordinated attack on mortgage fraud 

by updating analyses of Suspicious Activity Reports (SARs) to highlight current trends in 

mortgage loan fraud, and in loan modification and foreclosure rescue scams. FinCEN 

reports showed that mortgage loan fraud SAR filings continued to increase through 

2009. FinCEN also issued a report showing that after FinCEN issued an Advisory on 

loan modification scams, sampled SAR filings reporting such activity in every covered 

industry more than doubled over the entire preceding five-year period. FinCEN issued 

additional advisories to highlight updated scam techniques and reverse mortgage fraud 

schemes potentially related to the Federal Housing Administration (FHA) Home Equity 

Conversion Mortgage program; and

• Finalized or advanced several significant rulemakings to further strengthen the financial 

system’s resistance to financial crime. FinCEN issued a final rule enhancing domestic 

and international information sharing to thwart money laundering and terrorist finance by 

expanding access to FinCEN’s successful 314(a) program. FinCEN also issued Notices 

of Proposed Rulemaking that would establish a more comprehensive BSA regulatory 

framework to providers and sellers of prepaid access; require banks and money services 

businesses to report certain cross-border electronic transmittals of funds to FinCEN; and 

clarify foreign bank account reporting requirements.

FinCEN’s future plans in the regulatory area will improve its ability to strengthen financial 

system security and enhance U.S. national security. To ensure financial systems are resistant to 
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abuse by money launderers, terrorists and other perpetrators of financial fraud and crime, 

FinCEN will:

• Continue to advance regulatory initiatives designed to further protect the U.S. financial 

system from abuse while balancing their impact on the financial industry. This would 

include carefully considering public comment on and weighing changes to proposed rules 

as appropriate;

• Continue to conduct analysis in support of regulatory initiatives (such as identity theft) 

and further efforts to combat mortgage loan fraud, building off prior analysis efforts to 

identify emerging trends (such as commercial real estate fraud), and continue to consider 

advisories to financial institutions highlighting emerging risks or other appropriate 

regulatory options; and

• Continue to enhance proactive compliance and enforcement efforts by implementing 

further steps based on risks informed by analysis and law enforcement, including targeted 

steps to increase money transmitter registration. FinCEN will also continue to strengthen 

oversight of recently-covered industries under the BSA, by signing additional 

information sharing agreements with state insurance regulators and working 

cooperatively with the Internal Revenue Service and state regulators on consistent, riskbased examination procedures.

FinCEN’s efforts in the analytical area focus on developing products and services to enhance law 

enforcement’s detection and deterrence of domestic and international financial fraud, money 

laundering, terrorism financing, and other illicit activity. FinCEN intends to improve its expert 

analysis of BSA data to provide early warning of emerging trends of fraud and other criminal 

abuse. This includes information exchange with counterpart FIUs in 120 jurisdictions that are 

members of the Egmont Group.

In FY 2010, FinCEN:

• Leveraged the relationships and techniques developed in the mortgage fraud context to 

initiate similar efforts in the areas of health care fraud and securities fraud through its 

involvement in the Financial Fraud Enforcement Task Force. FinCEN also undertook 

efforts to expand information sharing across the U.S. Government in a coordinated 

manner, worked to enhance understanding of the value and utilization of BSA data for 

investigative purposes, and supported task force summit tour events with analytical 

targeting packages/demonstrations, through participation in committees and other 

working groups of the Financial Fraud Enforcement Task Force, including acting, along 

with the Executive Office for the U.S. Attorneys, as co-chair of the Task Force’s Training 

and Information Sharing Committee;

• Completed a joint study with the Mexican FIU of currency flows between the U.S and 

Mexico. The study provides a more accurate baseline of U.S. dollar currency activity in 

Mexico from which the U.S. and Mexico can more effectively measure the scope of bulk 

cash smuggling into Mexico and the effectiveness of future AML and cash interdiction 

efforts. The study also developed suspected Mexican money laundering targets and 

referred them to U.S. and Mexican law enforcement. FinCEN continues to coordinate 

investigative follow-up of these targets with U.S. law enforcement and develop plans for 

future targeting efforts. Completion of the study has positioned FinCEN well to respond 
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to new Mexican regulations related to U.S. dollar transactions. FinCEN dedicated a staff 

member to work with the Mexican FIU to deepen cooperation;

• Created and disseminated tactical financial intelligence reports to Egmont Group FIUs 

and managed case exchange with FIUs on behalf of U.S. law enforcement and regulatory 

agencies. These intelligence products are integral to domestic and foreign investigations 

of money laundering, financial fraud, and terrorist financing around the world; and

• Worked closely with developing the FIU in Afghanistan, FinTRACA. As a result of 

FinCEN’s efforts within the Egmont Group, FinTRACA was admitted to the Egmont 

Group in June 2010. Egmont Group membership is expected to lead to a considerably 

greater flow of financial intelligence between FinTRACA and other FIUs, including 

FinCEN. FinCEN also placed a staff member to work with the Afghanistan FIU to foster 

tactical information sharing between the FIU and U.S. law enforcement. 

FinCEN’s future plans in the analytical area will improve its ability to strengthen financial 

system security and enhance U.S. national security. To detect and deter financial fraud, money 

laundering, terrorism financing, and other illicit activity, FinCEN will:

• Continue to work with law enforcement, financial and international partners to combat 

Mexican cartel-related drug, gun and human smuggling operations in Mexico and along 

the Southwest Border by increasing and improving the sharing and analysis of related 

financial information;

• Support federal law enforcement efforts to combat health care fraud by initiating an 

advanced targeting process to identify potential health care fraud perpetrators and to 

provide analytical support to investigations and prosecutions;

• Expand the range of analytical products and identify more efficiencies in case 

management to respond to foreign FIU requests. FinCEN intends to increase the number 

of proactive intelligence reports sent to foreign counterpart FIUs. Proactive intelligence 

reports will enable foreign law enforcement agencies, to develop new cases or enhance 

existing ones; and

• Increase joint analytical projects with foreign FIU counterparts through intensified 

operational engagements with key strategic partner FIUs. FinCEN plans to replicate with 

other foreign FIUs a current analytical initiative involving FinCEN, the Mexican FIU, 

and the Internal Revenue Service’s Criminal Investigation Division (IRS-CI).

FinCEN’s efforts related to the efficient management, safeguarding, and use of BSA information 

focus on maximizing utilization by improving the overall information infrastructure and 

enhancing information technology management capabilities. In the past year, both currency 

transaction reports and SAR filings decreased for the first time ever, reflecting efforts to focus on 

data most needed, while data quality continues to increase. Improving data quality remains a 

priority for FinCEN. 

In FY 2010, FinCEN:

• Introduced additional field and business rule validations to batch data at E-Filing 

submission to improve data quality and provide faster error notification for SARs. Filers 

receive an e-mail if their submitted file has errors and they are directed to a designated 

error page to view batch validation error details;
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• Completed all of the project-level documentation defined in FinCEN’s System 

Development Life Cycle for the BSA IT Modernization initiative. This documentation 

provides the necessary business requirements and architectural foundational elements to 

enable FinCEN to proceed to the Design phase of the Program; and

• Implemented the E-Filing Work-In-Process (WIP) database to provide additional data 

validations and provide feedback to financial institutions.

FinCEN’s future plans will improve its ability to strengthen financial system security and 

enhance U.S. national security. To ensure efficient management, safeguarding and use of BSA 

information, FinCEN will:

• Continue to modernize BSA information management and analysis to equip law 

enforcement and financial industry regulators with better decision-making abilities, 

increase the value of BSA information through increased data integrity and analytical 

tools, and move Treasury to the ultimate goal of being a “paperless” agency. FinCEN 

plans to continue to utilize the Bureau of Public Debt (BPD) for IT modernization hosting 

to achieve data center efficiencies. 

• This multi-year program will: 

- Establish the production and disaster recovery infrastructure;

- Deploy the Registered User Portal, which will provide a common user interface and 

authentication process for accessing BSA data;

- Begin the development efforts to build the BSA new system of record and basic query 

capabilities; and

- Implement ability to discretely enter those select forms that are only currently 

accepted via paper filing. 

In FY 2012, FinCEN and the Administration propose a transfer of $30M from the Treasury 

Forfeiture Fund (see Administrative Provisions Sec. 125) to continue development and 

maintenance of the BSA Information Technology (IT) modernization program.

Going Green Goals

FinCEN supports the Administration’s Going Green goals. Additionally, FinCEN has a 

committee that routinely provides tips and suggestions to employees related to energy 

conservation. To improve Greenhouse Gas Reduction (GHG); FinCEN will reduce its Fleet size 

from four to three vehicles in FY 2011, and all vehicles are currently alternative-fuel vehicles. 

Further efforts include increased use of conference calls, video conferences and webinars, 

telework, and alternative work schedules. In addition, FinCEN has a very active and effective 

recycling program for paper, plastic, and aluminum, and procures paper that contains at least 30 

percent postconsumer fiber. Additionally, the bureau donated over 3,900 lbs of old computer 

equipment to UNICOR for recycling, and donated 61 LCD monitors and 15 laptop notebook 

computers to Computers for Learning (CFL). Finally, FinCEN implemented a Power 

Management Program on all computers to save energy; purchased 100 EPEAT- Register Gold 

Desktop Computers, 130 LCD Monitors, and 20 Laptop Notebook computers; transferred 183 

Blackberry Cell Phones to Treasury for reuse; and set up all printers for duplex printing.
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Section 2 – Budget Adjustments and Appropriation Language

2.1 – Budget Adjustments Table

Dollars in Thousands

Financial Crimes Enforcement Network FTE Amount

FY 2010 Enacted 331 $111,010

FY 2011 Annualized CR Level 327 $111,010

Changes to Base:

Adjustment to Reach Policy Level: - ($11,038)

Adjustment to Reach FY 2011 President's Policy Level - ($11,038)

Maintaining Current Levels (MCLs): - $897

Maintaining Current Levels (MCLs) - $897

Efficiencies, Savings & Base Reductions: (5) ($13,570)

Base Reduction to BSA IT Modernization - ($10,250)

Regulatory Support Efficiency Savings - ($1,017)

Information Technology Efficiency Savings - ($1,636)

Staffing Reduction from Attrition (5) ($667)

Subtotal FY 2012 Changes to Base (5) ($23,711)

Total FY 2012 Base 322 $87,299

Program Changes:

Program Decreases: (18) ($3,002)

Reduce Field Law Enforcement Support (3) ($683)

Reduce Intelligence Support to External Agencies (6) ($968)

Consolidate State and Local Access to BSA Data (9) ($1,351)

Subtotal FY 2012 Program Changes (18) ($3,002)

Total FY 2012 Request 304 $84,297

Transfers - $30,000

Total FY 2012 Request (Net) 304 $114,297

2A – Budget Increases and Decreases Description

Adjustment to Reach Policy Level ..........................................................-$11,038,000 / +0 FTE

Adjustment to Reach FY 2011 President's Policy Level -$11,038,000 / +0 FTE 

Adjustment from the FY 2011 Annualized Continuing Resolution (CR) Rate to reach the FY 

2011 President's Policy Level. The President's Policy Level is equal to the FY 2011 President's 

Budget as adjusted for the proposed pay freeze.

Maintaining Current Levels (MCLs) .........................................................+$897,000 / +0 FTE

Maintaining Current Levels (MCLs) +$897,000 / +0 FTE 

Funds are requested for inflation adjustments in non-labor expenses such as GSA rent 

adjustments, postage, supplies and equipment and health benefits and the increase in Federal 

Employee Retirement System participation. No inflation adjustment is requested for pay in FY 

2012.

Efficiencies, Savings & Base Reductions ................................................-$13,570,000 / -5 FTE

Base Reduction to BSA IT Modernization -$10,250,000 / +0 FTE 

BSA IT Modernization program will be funded with Forfeiture Fund surplus in FY 2012, thereby 

reducing the discretionary request by an additional $10.250 million. Total project funding 

remains the same.
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Regulatory Support Efficiency Savings -$1,017,000 / +0 FTE 

FinCEN will achieve efficiency savings through targeted regulatory support efforts, 

centralization of money services business (MSB) outreach activities, and change in distribution 

methodology for MSB brochure materials. The impact of these reductions will be mitigated 

through future consolidation of call centers; centralization of outreach activities; additional 

outreach support by FinCEN staff; and greater reliance on FinCEN's public website to distribute 

MSB materials, supporting Treasury's paperless initiative.

Information Technology Efficiency Savings -$1,636,000 / +0 FTE 

In FY 2012, the BSA IT Modernization program will roll out new capabilities for BSA E-Filing 

and a new analytical tool. Therefore, FinCEN proposes to eliminate development funding for 

stand-alone system enhancements that could be rolled into the BSA IT Modernization umbrella 

during FY 2012. FinCEN will also achieve efficiencies through consolidation of information 

technology contracts, leveraging Treasury strategic sourcing initiatives, and other related 

efficiencies.

Staffing Reduction from Attrition -$667,000 / -5 FTE 

Reductions were identified from efficiencies achieved in administrative staffing support and 

absorption of workload associated with positions lost through attrition.

Program Decreases ...................................................................................-$3,002,000 / -18 FTE

Reduce Field Law Enforcement Support -$683,000 / -3 FTE 

Reductions are identified from discontinuance of a liaison position at the Federal Law 

Enforcement Training Center (FLETC), and from decreases in field positions located in High 

Intensity Financial Crime Areas (HIFCAs). FinCEN will continue to support law enforcement 

from its headquarters.

Reduce Intelligence Support to External Agencies -$968,000 / -6 FTE 

This reduction will reduce analytical support to external customers in support of their national 

security, counter terrorism financing, and law enforcement matters. FinCEN will continue to 

carry-out limited case support and support to FinCEN's analytical initiatives that require national 

security information. FinCEN will also provide access to BSA information for external agencies 

through appropriate information sharing protocols.

Consolidate State and Local Access to BSA Data -$1,351,000 / -9 FTE 

This reduction will limit direct access to BSA data to only state coordinators, canceling 142 

current state and local BSA direct access agreements for law enforcement and regulators. The 

state coordinators and FinCEN analysts would then be asked to provide access to the BSA by 

fulfilling query requests from those customers that previously had direct access. These actions 

allow FinCEN to reduce training, investigative and administrative support to state and local 

users, and inspections and monitoring of BSA data for appropriate use.

Transfers ..................................................................................................+$30,000,000 / +0 FTE

Proposed Transfer from TFF to Support BSA IT Modernization Continuing Efforts 

+$30,000,000 / +0 FTE 

The BSA IT Modernization will be funded using a transfer from Treasury Forfeiture Fund (see 
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Administrative Provisions Sec. 125) to support continuing development and maintenance. This 

transfer allows Treasury to use asset forfeiture to support the development of a tool that will 

support law enforcement's anti-money laundering and counter-terrorism financing efforts.
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2.2 – Operating Levels Table

Dollars in Thousands

Financial Crimes Enforcement 

Network

FY 2010

Enacted

FY 2011

Annualized CR 

Level

Proposed 

Reprogram

mings

FY 2011

Proposed Operating 

Level

FY 2012 

Request

FTE 331 327 - 327 304

Object Classification

11.1 - Full-time permanent $36,108 $37,130 $0 $37,130 $34,314

11.3 - Other than full-time permanent $294 $304 $0 $304 $287

11.5 - Other personnel 

compensation $545 $564 $0 $564 $526

12 - Personnel benefits $9,420 $9,597 $0 $9,597 $8,986

21 - Travel and transportation of 

persons $1,153 $844 $0 $844 $758

23.1 - Rental payments to GSA $5,380 $5,379 $0 $5,379 $5,424

23.2 - Rental payments to others $71 $71 $0 $71 $71

23.3 - Communication, utilities, and 

misc charges $1,399 $1,415 $0 $1,415 $1,313

24 - Printing and reproduction $454 $459 $0 $459 $263

25.1 - Advisory and assistance 

services $1,829 $1,849 $0 $1,849 $1,865

25.2 - Other services $13,178 $13,064 $0 $13,064 $7,969

25.3 - Other purchases of goods and 

services from Govt. accounts $14,545 $14,595 $0 $14,595 $14,415

25.4 - Operation and maintenance of 

facilities $968 $737 $0 $737 $0

25.6 - Medical care $155 $156 $0 $156 $158

25.7 - Operation and maintenance of 

equip $5,056 $5,118 $0 $5,118 $5,166

26 - Supplies and materials $449 $450 $0 $450 $431

31 - Equipment $20,006 $19,278 $0 $19,278 $2,351

Total Budget Authority $111,010 $111,010 $0 $111,010 $84,297

Budget Activities

BSA Administration and Analysis $101,694 $111,010 $0 $101,694 $84,297

Regulatory Support Programs $9,316 $0 $0 $9,316 $0

Total Budget Authority $111,010 $111,010 $0 $111,010 $84,297
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2.3 – Appropriations Detail Table

Dollars in Thousands

2B – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes

DEPARTMENT OF THE TREASURY

FINANCIAL CRIMES ENFORCEMENT NETWORK

Federal Funds

SALARIES AND EXPENSES:

For necessary expenses of the Financial Crimes Enforcement 

Network, including hire of passenger motor vehicles; travel and 

training expenses, including for course development, of nonFederal and foreign government personnel to attend meetings 

and training concerned with domestic and foreign financial 

intelligence activities, law enforcement, and financial 

regulation; not to exceed $14,000 for official reception and 

representation expenses; and for assistance to Federal law 

enforcement agencies, with or without reimbursement, 

$84,297,000 of which not to exceed $15,835,000 shall remain 

available until September 30, 2014: Provided, that funds 

appropriated in this account may be used to procure personal 

services contracts. 

To simplify the fund 

availability structure, 

FinCEN is proposing to 

eliminate the two-year 

fund. The funding 

available for three years 

(i.e., until September 30, 

2014) is required due to the 

longer lead-time needed to 

execute information 

technology efforts and 

special analytical, 

regulatory, or international 

partnership efforts. This 

allows these projects to be 

executed in a single 

appropriation regardless of 

lead-time for acquisition.

2C – Legislative Proposals

FinCEN is proposing five technical amendments to Titles 31 and 12 that would make 

improvements in four important areas. The first amendment provides authority to rely on 

examinations conducted by state supervisory agencies for nonbank financial institutions lacking 

a Federal regulator, which would capture most nonbank financial institutions currently subject to 

Internal Revenue Service (IRS) examination as delegated through a memorandum of 

understanding. The second amendment increases information sharing between FinCEN and 

FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

Appropriated Resources:

Collect the Revenue 329 $93,494 331 $101,694 327 $101,694 304 $84,297 -8.16% -17.11%

Protect the Public 8,716 9,316 9,316 -100.00%

Subtotal New Appropriated Resources 329 $102,210 331 $111,010 327 $111,010 304 $84,297 -8.16% -24.06%

Other Resources:

Offsetting Collections - Reimbursable 2 14,200 1 20,000 1 20,000 1 3,000 0.00% -85.00%

Available multi-year/no-year funds 15,526 20,526 25,420 15,000 -26.92%

Transfers In/Out 30,000

Recoveries 20 500 500 500 0.00%

Subtotal Other Resources 2 29,746 1 41,026 1 45,920 1 48,500 0.00% 18.22%

Total Resources Available for Obligation 331 $131,956 332 $152,036 328 $156,930 305 $132,797 -8.13% -12.65%

Resources Available for Obligation FY 2010 

Obligations

FY 2010 

Enacted

 FY 2011 

Annualized 

CR Level

FY 2012 

Request

% Change 

FY 2010 

to FY 2012
FinCEN - 12

counterpart anti-money laundering/counter-terrorist financing regulators. Specifically, this 

amendment provides consistency between how FinCEN shares information in its capacity as a 

regulator and information sharing that currently exists between federal financial regulators and 

their foreign counterparts. The remaining amendments expand the universe of individuals 

covered by the prohibition on SAR disclosures and explicitly exempt all BSA data from 

disclosure under any state law or regulation providing public access to information. The specific 

changes to the amendment language are outlined below.

Sec. 120. Section 5318(a)(1) of Title 31, United States Code (relating to compliance, exemptions, 

and summons authority), is amended by - (1) Inserting after "appropriate" "federal or (in the 

case of financial institutions without a federal supervisor) state"; and (2) Inserting after 

"Service." , "In lieu of delegating such authority to a state supervisory agency, the Secretary is 

also authorized to rely on examinations conducted by a state supervisory agency of a category of 

financial institution. The Secretary may only rely on such state examinations if the Secretary 

determines that under the laws of the state, the category of financial institution is required to 

comply with this subchapter and regulations prescribed under this subchapter, or the state 

supervisory agency is authorized to ensure that the category of financial institution complies 

with this subchapter and regulations prescribed under this subchapter."

Sec. 121. Public Law 91-508, as amended (12 U.S.C. 1958 et seq.) is amended in section 128, by 

(1) Striking "sections 1730d (1) and" inserting in lieu thereof “section”; (2) Striking "bank 

supervisory agency, or other"; (3) Inserting after "appropriate" , "federal or (in the case of 

financial institutions without a federal supervisor) state"; and (4) Inserting after "agency." "In 

lieu of delegating such responsibility to a state supervisory agency, the Secretary is also 

authorized to rely on examinations conducted by a state supervisory agency of a category of 

financial institution. The Secretary may only rely on such state examinations if the Secretary 

determines that under the laws of the state, the category of financial institution is required to 

comply with this chapter and section 1829b (and regulations prescribed under this chapter and 

section 1829b), or the state supervisory agency is authorized to ensure that the category of 

financial institution complies with this chapter and section 1829b (and regulations prescribed 

under this chapter and section 1829b)."

Sec. 122. Section 310(b)(2)(E) of Title 31, United States Code (relating to the Financial Crimes 

Enforcement Network), is amended by inserting after "Federal" the first time that it appears, 

"and foreign".

Sec. 123. Section 5318(g)(2)(A) of Title 31, United States Code (relating to reporting of 

suspicious transactions), is amended by - (1) Inserting after "employee." at the end of paragraph 

(ii) "; and"; and (2) Inserting after "; and" "(iii) no other person that the Secretary may 

prescribe by regulation, who has knowledge that such report was made, may disclose to any 

person involved in the transaction that the transaction has been reported."

Sec. 124. Section 5319 of Title 31, United States Code (relating to availability of reports), is 

amended by inserting after "title 5", ", or any State law having or intended to have a similar 

effect."
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Section 3 – Budget and Performance Plan

This table lists all FY 2012 resources by strategic goal, objective and outcome outlined in the FY 

2007-2012 Treasury Department Strategic Plan. The Treasury Strategic Plan provides a 

description of what the agency intends to accomplish over the next five years.

For detailed information about the FY 2007-2012 Treasury Strategic Plan, please go to: 

http://www.treasury.gov/about/budget-performance/strategic-plan/Pages/index.aspx

3.1 – Budget by Strategic Outcome

Dollars in Thousands

Treasury Strategic Outcome FY 2010 

Enacted

FY 2011 

Annualized 

CR Level

FY 2012 

Request

% Change

FY10 to FY12

 Safer and more transparent U.S. and international 

financial systems 131,010 131,010 117,297 -10.47%

Total $131,010 $131,010 $117,297 -10.47%

3A - BSA Administration and Analysis ($84,297,000 from direct appropriations, $30,000,000 

from transfers, and $3,000,000 from reimbursable programs): This activity comprises 

FinCEN’s efforts to administer the BSA, including promulgating regulations, providing outreach 

and issuing guidance to the regulated industries, providing oversight of BSA compliance, 

initiating enforcement actions, and, with the IRS, managing the information reported by the 

regulated industries, as well BSA compliance of non-bank financial institutions. Analytical 

programs include support to U.S. law enforcement and international FIUs in combating financial 

fraud and crime by facilitating the exchange of investigative information, including with foreign 

counterpart FIUs; identifying foreign and domestic financial fraud, money laundering, and 

terrorist financing trends, patterns, and techniques; and liaison with and support of intelligence 

initiatives within the intelligence community and within Treasury. This activity also 

incorporates efforts to support large-scale, complex law enforcement investigations involving 

financial fraud, terrorist financing, money laundering, and other financial crimes. 

FinCEN works closely with federal and state regulatory agencies that examine financial 

institutions for BSA compliance to ensure consistency across regulated industries. Through 

these efforts and direct outreach, FinCEN also assists regulated financial institutions in 

establishing risk-based anti-money laundering programs with appropriate policies, procedures, 

and internal controls and maintaining records and filing reports on certain types of financial 

activity pursuant to the BSA. As appropriate, FinCEN investigates alleged violations by 

financial institutions, issues letters of caution or warning, and seeks injunctions; additionally, 

when required, FinCEN imposes civil monetary penalties for egregious BSA violations, typically 

in conjunction with partner federal and state agencies. 

FinCEN supports law enforcement agencies, intelligence agencies, and foreign FIUs 

investigating financial fraud and crimes by providing specialized and unique analysis of BSA 

data along with information from law enforcement, intelligence, and commercial sources. 

FinCEN’s analysis also supports regulatory and other policy decisions. The analysis includes 

development of threat assessments, industry reports, and technical guides describing financial 
FinCEN - 14

transaction mechanisms. Additionally, FinCEN identifies individuals and networks involved in 

suspicious financial activity, referring that information to appropriate law enforcement agencies.

In the global arena, FinCEN’s activities include: supporting international initiatives to educate 

other jurisdictions about the BSA regulatory regime; working to establish international antimoney laundering/counter-terrorist financing regulatory standards and norms; and improving 

information exchange among FIUs through substantial engagement with the Egmont Group.

As administrator of the BSA, FinCEN must ensure the effective management, accessibility, 

dissemination, and use of the highly sensitive confidential information collected under the Act. 

FinCEN provides authorized law enforcement, regulatory, and intelligence agencies direct access 

to BSA information.

Other Resources: Offsetting collections totaling $3,000,000 are collected to support joint 

activities with other agencies. In addition, $30,000,000 will be transferred from Treasury 

Forfeiture Fund (TFF) (see Administrative Provisions Sec. 125) to continue development and 

maintenance of the BSA IT modernization program. 

3.2.1 BSA Administration and Analysis Budget and Performance Plan

BSA Administration and Analysis Budget Activity

Resource Level FY 2008 FY 2009 FY 2010 FY 2011 FY 2012

Obligated Obligated Enacted Annualized CR 

Level

Request

 Appropriated Resources $68,606 $82,287 $101,694 $101,694 $84,297

 Reimbursable Resources $4,310 $6,000 $20,000 $20,000 $3,000

Total Resources $72,916 $88,287 $121,694 $121,694 $87,297

Transfers $0 $0 $0 $0 $30,000

Total $72,916 $88,287 $121,694 $121,694 $117,297

Budget Activity Total $72,916 $88,287 $121,694 $121,694 $117,297

Measure FY 2008 FY 2009 FY 2010 FY 2011 FY 2012

Actual Actual Actual Target Target

Percentage of Customers Satisfied with the BSA E-Filing (Oe) 93.0 94.0 96.0 90.0 92.0

Percentage of Domestic Law Enforcement and Foreign Financial 

Intelligence Units Finding FinCEN's Analytical Reports Highly 

Valuable

83.0 81.0 80.0 80.0 80.0

Percentage of Federal and State Regulatory Agencies with 

Memoranda of Understanding/Information Sharing Agreements 

(Ot)

41.0 43.0 46.0 46.0 50.0

Percentage of FinCEN's Compliance MOU Holders Finding 

FinCEN's Information Exchange Valuable to Improve the BSA 

Consistency and Compliance of the Financial System (Oe)

64.0 82.0 86.0 86.0 86.0

Percentage of FinCEN's Regulatory Resource Center Customers 

Rating the Guidance Received as Understandable (Oe)

94.0 94.0 92.0 90.0 90.0

Key: Oe - Outcome Measure, E - Efficiency Measure, Ot - Output/Workload Measure, M - Management/Cust. Satisfaction, DISC -

Discontinued, and B - Baseline
FinCEN - 15

Description of Performance: In the regulatory area, FinCEN continues to increase activities to 

monitor financial institutions examined for BSA compliance by state and federal regulators 

through the establishment of MOUs to exchange compliance information. In 2010, FinCEN met 

its target of 46 percent of federal and state regulatory agencies with MOU/information sharing 

agreements. FinCEN achieved its target by finalizing four additional MOUs with state regulatory 

agencies. FinCEN will continue collaborating with state insurance agencies and other regulatory 

agencies to sign additional agreements to meet future targets. In FY 2012, FinCEN expects to 

meet the target of 50 percent.

FinCEN surveys its compliance MOU holders to determine the impact of the information 

exchange to improve the BSA consistency and compliance of the financial system. In FY 2010 

FinCEN surpassed its target of 68 percent rating the information exchange valuable with 86 

percent. FinCEN attributes a portion of this success to the distribution of analytic information to 

the MOU holders throughout the fiscal year. To achieve future targets, FinCEN will continue to 

facilitate routine discussions with the MOU holders. In FY 2012, FinCEN expects to meet the 

target of 86 percent.

FinCEN’s goal to provide financial institutions with understandable guidance through the BSA 

Resource Center is critical to institutions establishing anti-money laundering programs that 

comply with the BSA. The FY 2010 goal was to maintain a 90 percent satisfaction level for 

customers rating the guidance as “understandable,” and FinCEN surpassed its goal with 92 

percent. FinCEN attainted this success by responding timely (within 24 hours of the inquiry), 

providing a high level of service. In order to achieve future targets, FinCEN will continue to 

make guidance available on the Internet, accept and analyze customer feedback, and conduct 

surveys to measure customer satisfaction. In FY 2012, FinCEN expects to continue to meet the 

target maintaining a consistently high satisfaction level of at least 90 percent.

FinCEN also works closely with its regulatory partners to take enforcement action against 

financial institutions that systemically and egregiously violate the provisions of the BSA, 

including through imposition of civil money penalties when appropriate. Timely enforcement 

action is essential to deter non-compliance with the BSA. In fiscal year 2010, FinCEN met its 

target for the average time to process enforcement matters in one year with an average time of 

0.8 year. FinCEN will continue to actively manage casework to meet future targets. In FY 

2012, FinCEN expects to continue to meet the target of 1.0 years. 

In the analytical area, FinCEN supports domestic law enforcement and international FIU partners 

by providing analyses of BSA information, and measures the percentage of customers finding 

FinCEN’s analytic reports highly valuable. The measure closely ties to how BSA information is 

used by law enforcement and international FIUs to identify, investigate, and prevent abuse of the 

financial system. In FY 2010, 80 percent of the respondents rated the analytic products as highly 

valuable. FinCEN narrowly missed its target of 81 percent. FinCEN attributes this to a need to 

enhance communication with and understanding of law enforcement partners’ needs. FinCEN 

has developed a strategy to increase communication with law enforcement partners and will 

continue efforts to ensure its products and services meet those needs. In FY 2012, FinCEN 

expects to meet its target of 80 percent. 
FinCEN - 16

In the efficient management, safeguarding, and use of BSA information, FinCEN conducts a 

survey of the users of the BSA E-Filing system to determine the overall satisfaction level and to 

identify where improvements are needed. The FY 2010 target was to maintain at least a 90 

percent satisfaction level, and FinCEN exceeded its target with 96 percent. FinCEN attributes 

this to a result of continued outreach, the implementation of a more industry-friendly forms 

submission software (Adobe), and the receipt/acknowledgements and data validations specific to 

Suspicious Activity Reports now available to the filing community. FinCEN will continue 

outreach to E-Filers and ensure the technology supports the demand to achieve future targets. In 

FY 2012, FinCEN expects to meet the target of 92 percent. 

FinCEN also began tracking the value of the BSA information to law enforcement and regulatory 

agency users with direct access to the BSA data. This is a composite measure compiled from 

survey results. The survey looks at the value of BSA data, such as whether the data provided 

unknown information, supplemented or expanded known information, verified information, 

helped identify new leads, opened a new investigation or examination, supported an existing 

investigation or examination, and provided information for an investigative or examination 

report. The FY 2010 baseline for the percentage of direct access users finding the BSA data 

provides valuable information toward the detection and deterrence of financial crime and the 

transparency and protection of the financial systems was 87 percent. 

3B - Regulatory Support Programs (No funding): FinCEN is proposing to eliminate the 

Regulatory Support Program budget activity along with the related two year fund availability. This 

program has matured and is now an integrated part of FinCEN’s activities, thus the separate 

identification and extended funding availability is no longer required.

3.2.2 Regulatory Support Programs Budget and Performance Plan

Regulatory Support Programs Budget Activity

Resource Level FY 2008 FY 2009 FY 2010 FY 2011 FY 2012

Obligated Obligated Enacted Annualized CR 

Level

Request

 Appropriated Resources $8,941 $9,178 $9,316 $9,316 $0

 Reimbursable Resources $0 $0 $0 $0 $0

Total Resources $8,941 $9,178 $9,316 $9,316 $0

Budget Activity Total $8,941 $9,178 $9,316 $9,316 $0

For detailed information about each performance measure, including definition, verification and 

validation, please go to: http://www.treasury.gov/offices/management/dcfo/accountabilityreports/
FinCEN - 17

Section 4 – Supporting Materials

4A – Human Capital Strategy Description

FinCEN’s Human Capital Strategy is best described by its organizational vision outlined in the 

2008-2012 Strategic Plan (http://www.fincen.gov/about_fincen/wwd/strategic.html). That vision 

is to have a well-managed environment where expert staff act swiftly, creatively, and 

collaboratively to address the threats posed to the domestic and international financial system by 

money launders, terrorists and their financial supporters, other threats to national security and 

perpetrators of financial crime. 

FinCEN continues to work to improve its employee satisfaction results. The bureau recently 

received the results of the 2010 Employee Viewpoint Survey and found that its scores have 

continued to improve, resulting in an overall Bureau rating above the government average. 

FinCEN realized significant improvement in those areas where it most focused attention (i.e., 

performance management, communication, training, telework and leadership) in terms of steps 

for improvement from the 2008 survey. The bureau is finalizing its 2010 – 2011 action plan for 

improvement from the 2010 survey. 

In FY 2010, FinCEN continued several successful work life programs to improve employee 

morale including: Fitness Center Reimbursement, Student Loan Repayment, Alternate Work 

Schedule, and telework. Participation in the Fitness Center Reimbursement Program increased 

from 70 employees (22 percent) to 84 employees (26 percent). Twenty-nine employees have 

participated in the Student Loan Repayment Program since its implementation and FinCEN has 

facilitated the repayment of six employee loans in full. Informal feedback showed increased 

employee satisfaction and retention since a three year service agreement is completed upon 

entering the program. FinCEN offers employees flexibility with both Alternate Work Schedules 

(AWS) and telework programs. Currently, 56 percent of FinCEN employees participate in the 

telework program. To round out work life program offerings, FinCEN promotes the Employee 

Assistance Program (EAP) and Worklife4You, a Resources and Referral Service. Both EAP and 

WorkLife4You offer free services to employees, informational emails, and seminars on physical 

and mental health and wellness issues. 

FinCEN’s continued focus on work life programs netted improved results when comparing 

surveys across years. In the 2010 survey, 85 percent of FinCEN of employees indicated 

satisfaction with AWS and 80 percent felt that their manager supported their need to balance 

work and other life issues. Further, 58 percent felt that senior leaders demonstrate support for 

the Worklife Program. Specifically, 63 percent were satisfied with the telework program, up 

from 30 percent in 2008. Seventy six percent of the workforce is satisfied with the Health and 

Wellness programs offered and 60 percent with the EAP program. In addition, the FinCEN 

Worklife Coordinator is a Certified Worklife Professional. Currently, there are only 13 of these 

individuals in Federal Government and two are employed by Treasury.

FinCEN continues to build a results-oriented, high performing workforce. FinCEN’s current five 

tier performance management system requires that each manager place employees on 

performance standards that include individual commitments linked directly to the strategic plan. 

This performance management system enables managers to differentiate performance levels 
FinCEN - 18

among employees and establish employee’s expectations and accountability for meeting 

specified performance goals and targets. To further develop each employee, managers and 

employees collaboratively develop and agree upon an annual individual development plan to 

identify areas for career growth and development. 

Based upon OPM and employee feedback, FinCEN developed a new Performance Management 

Program and Awards and Recognition System for implementation in FY 2011. In the first two 

quarters of FY 2010, FinCEN reviewed the current policy, surveyed employees, launched an 

employee feedback/steering group, identified themes and areas requiring adjustment, and drafted 

a policy and supporting handbook that capture these themes combined with OPM input. This 

new policy has been approved and training was provided. Any award program developed will 

feature the extremely popular Annual Director’s Awards and Recognition Program. This 

program celebrates FinCEN employee achievements in leadership, visionary, customer service, 

team work, and diversity and is a highlight of the fall season. 

FinCEN continues to offer a comprehensive leadership development program, expand leader 

programs/resources, implement strategic on-boarding, review retention data, expand rotational 

assignments, build upon inter and intra divisional activities, and improve communication. 

The Associate Directors who lead FinCEN’s five divisions have fostered team building and 

expanded cross-divisional activities. The 2008 Human Capital Survey results were the first time 

that the data was available by division, and FinCEN was able to develop division specific 

initiatives. Analysts across the bureau now meet periodically to build and strengthen 

relationships, and share analytical tips and processes. This team building effort continues and 

the organization continues to benefit from the sharing of information and the fostering of a 

greater understanding of incoming data and its impact on further analysis. 

Leadership and Workforce Planning

Although the bureau’s overall average age and average years of service is low as compared to 

other Treasury bureaus and the federal government, FinCEN continues to assess and develop its 

future workforce. FinCEN offers a wealth of leadership opportunities, both formal and informal, 

extensive leader resources, a formal mentoring program, a formal rotational assignment program, 

and extensive skill assessments and training development planning to engage employees.

In FY 2010, FinCEN continued its aggressive leadership development plan to strengthen the 

skills of its current leaders and promote leadership skills at all levels. Implementation included 

360 assessments for executives and supervisors, mandatory training for new supervisors, and 

annual completion of 24 hours of supervisory or leadership-focused continuing education. To 

meet these goals, FinCEN conducted in-house training for supervisors that included coaching 

and mentoring skills, relationship building, performance management, and change management. 

In FY 2010, FinCEN’s executive team started receiving individual and team executive coaching. 

To serve both supervisors and potential leaders, FinCEN’s new Leadership Webinar Series made 

a range of topics available to all employees on a biweekly basis. In FY 2010, FinCEN launched 

a Mentoring Program, pairing twenty individuals together for a year-long plan for training and 

development. FinCEN also initiated its Thought Leader Series. The goal of the series is to bring 
FinCEN - 19

acclaimed authors to FinCEN to provoke employees’ thinking and offer new perspectives on 

leadership. FinCEN also delivered in-house instruction to develop leadership skills in nonsupervisors and to empower all employees in accomplishing the bureau’s mission. 

FinCEN expanded resources to all leaders by creating a Supervisor’s Toolkit designed for both 

new and experienced supervisors to facilitate understanding of non-HR topics. This on-line 

resource is a fresh approach and shortcut to specific information supervisors need to perform 

their jobs and includes checklists, summary charts, explanations, and links. 

FinCEN continues to monitor its skills mix and perform comprehensive skill assessments to 

design training programs. FinCEN is committed to ensuring that employees possess the skills 

and knowledge needed to perform their jobs, keep their skills current and prepare for 

advancement. FinCEN continues to assess skills for its mission critical occupations: Intelligence 

Research Specialists, Regulatory Specialists, and Law Enforcement Liaison Specialists. In FY 

2009, results of those skills gap assessments prompted revisions to the corresponding training 

development plans, identified and prompted delivery of essential in-house training to close skill 

gaps, accelerated the frequency at which FinCEN’s BSA Training Program is offered, and 

identified the need for a new Advanced Strategic and Complex Analysis training course, which 

is scheduled to start at the end of FY 2010. In FY 2010, technical skills training courses were 

brought in-house for FinCEN’s analysts and regulatory specialists. Those courses focused on 

high level analysis, writing, communication and assessment of written products.

FinCEN’s Rotational Assignment Program is another important method for skills enhancement 

and sharing expertise within and outside the bureau. Since its launch in FY 2009, qualified and 

motivated employees have continued to further their own learning and career development, while 

elevating communication and knowledge in their own rotational destinations. Several FinCEN 

rotational assignments were posted on Treasury’s Virtual Career Center portal and two Treasury 

employees accepted rotations into FinCEN.

FinCEN utilizes various hiring authorities and flexibilities. Annually, FinCEN hires a number of 

students under the Student Temporary Employment Program (STEP). In addition, FinCEN often 

utilizes the Veterans Employment Opportunity Act (VEOA) and Schedule A Disability 

Appointment authority. FinCEN continued to reduce the amount of time it takes to hire 

employees from 45 days to less than 32 days during the last four quarters. 

Recruitment and Diversity 

FinCEN continued to take steps to attract a diverse workforce, which included partnering with 

diverse academic groups to attract student interns of diverse background and establishing 

contacts with special interest groups to attract applicants from diverse populations. FinCEN 

continued a mandatory Equal Employment Opportunity (EEO)/Diversity element in all 

supervisory performance plans to address EEO principles, workplace conflict, EEO plans, and 

diversity hiring requirements. 

FinCEN continues to offer a Diversity Day Training conference for all employees. The 2009 

activities focused on “Communicating Across Differences.” Noted leadership expert Warren 

Blank led a workshop on personal responsibility and leadership. In 2010, FinCEN held its 9th 
FinCEN - 20

Diversity Day and featured a workshop led by Mr. Howard Ross. Mr. Ross is an expert in 

diversity, inclusion and unconscious bias, and helps organizations understand how individuals 

and organizations must develop strategies to unmask unconscious preconceptions regarding team 

members.
FinCEN - 21

4.1 – Summary of IT Resources Table

Dollars in Thousands

Major IT Investments / Funding Source Budget Activity

FY 2009 

Enacted

FY 2010 

Enacted

% Change 

from FY 2009 

to FY 2010

FY 2011 

Annualized

CR Level

FY 2012 

Request

% Change 

from FY 2010 

to FY 2012

BSA Information Technology Modernization* BSA Administration and 

Analysis $0 $31,487 N/A $32,200 $32,200 2.3%

Subtotal, Major IT Investments

BSA Administration 

and Analysis $0 $31,487 N/A $32,200 $32,200 2.3%

Non-Major IT Investments

BSA Administration 

and Analysis $18,108 $12,535 -30.8% $11,290 $9,718 -22.5%

Infrastructure Investments

BSA Administration 

and Analysis $9,800 $11,374 16.1% $10,621 $10,647 -6.4%

Enterprise Architecture

BSA Administration 

and Analysis $385 $250 -35.1% $453 $457 82.8%

Enterprise Identity and Access Management

BSA Administration 

and Analysis $299 $304

Total IT Investments

BSA Administration 

and Analysis $28,293 $55,646 96.7% $54,863 $53,326 -4.2%

* BSA IT Modernization project includes a transfer of $30 million funding from Treasury Forfeiture Fund.
FinCEN - 22

4B – Information Technology Strategy

As the administrator of the BSA, FinCEN receives valuable information reported and collected 

under BSA requirements, which totaled approximately 17 million filings in FY 2009. The 

bureau’s mission is to enhance U.S. national security, deter and detect criminal activity, and 

safeguard financial systems from abuse by promoting transparency in the U.S. and international 

financial systems. FinCEN’s mission supports Treasury’s strategic goal to prevent terrorism and 

promote the nation’s security through strengthened financial systems. To successfully fulfill its 

mission, FinCEN relies on secure, advanced information technology (IT) to manage the 

collection, processing, storage, and dissemination of BSA information that contributes to the 

soundness and confidence in America’s financial system.

FinCEN’s IT Strategy takes into account the growing need for financial institutions to meet 

obligations as efficiently as possible, while ensuring that national and global law enforcement 

agencies receive accurate, timely, and reliable BSA information to track money trails, identify 

money laundering, and unravel terrorist financing networks. FinCEN’s IT Strategy focuses on 

the critical need to improve the quality and accessibility of its data and increase responsiveness 

to stakeholders by introducing flexible and innovative technical solutions.

A major component of FinCEN’s IT Strategy is the bureau’s information technology 

modernization vision and strategy (IT MV&S) and resulting Enterprise Transition Strategy, 

which serves as the roadmap for aligning its IT portfolio with its business objectives and 

processes and has resulted in the multi-year BSA IT Modernization program. By establishing an 

enterprise-wide information management and analysis framework, law enforcement and financial 

industry regulators will be equipped with better decision-making abilities and increased value of 

BSA information through enhanced data integrity and analytical tools. BSA IT Modernization 

will help FinCEN move away from custom coded legacy applications which are complex and 

difficult to maintain to a more modern environment based on Commercial Off the Shelf (COTS) 

products and standardized data formats. FinCEN is supporting Treasury/OMB’s goal of data 

center consolidation by hosting its production environments at the Bureau of Public Debt (BPD). 

In addition, FinCEN is working with OMB to develop National Information Exchange Model

standards for data exchange with law enforcement and intelligence communities.

The BSA IT Modernization effort helps move Treasury towards a “paperless” environment by 

increasing electronic filing and enabling future Treasury savings in paper-processing costs, while 

enabling industry savings due to the reduction of filing complexity. Increasing the automated 

collection of BSA data also decreases the amount of time it takes to make critical information 

available to FinCEN’s stakeholders. Providing more reliable and valid data in pre-defined 

formats enables a higher confidence in the data and reduces the time to decipher and interpret 

data.

FinCEN is employing a System Development Life Cycle (SDLC) methodology and proven 

Program Management methodologies, such as the Project Management Body of Knowledge, to 

manage the BSA IT Modernization program. Before FinCEN can proceed through each phase of 

the program, it must demonstrate completion of all requisite activities and receive approval from 

the Modernization Executive Group, the highest level of Governance comprised of the Treasury 

CIO, FinCEN Director, and IRS Deputy Commissioner for Operations and Maintenance. 
FinCEN - 23

FinCEN utilizes an Integrated Master Schedule (IMS) to depict all project activities, including 

cross project dependencies and resource loading. The IMS also serve as the foundation for 

conducting Earned Value Management, which effectively integrates the program’s scope of work 

with schedule and cost elements for optimum project planning and control. The IMS will allow 

FinCEN to perform wellness analysis to help ensure adherence to “best practices”, qualitative 

analysis to help ensure appropriate content, and performance analysis, such as critical path, 

schedule variance, and schedule trend analysis. These various analysis tools will help the bureau 

stay abreast at any given time of the cost and schedule for the program and take timely remedial 

actions as necessary.

In FY 2010, FinCEN completed the project-level work to base-line the requirements and 

technical architecture. FinCEN obtained approval from the Modernization Executive Group to 

begin the design phase in May 2010. FinCEN has subsequently awarded the necessary task 

orders under the Indefinite Delivery/Indefinite Quantity contract for IT services support and 

launched the design effort.