Department of the Treasury 

Financial Crimes Enforcement 

Network 

Congressional Budget 

Justification and Annual 

Performance Plan and Report 

FY 2023 
FinCEN - 2 

Table of Contents

Section I – Budget Request........................................................................................................... 3

A – Mission Statement ................................................................................................................ 3

B – Summary of the Request ...................................................................................................... 3

1.1 – Appropriations Detail Table .............................................................................................. 3

1.2 – Budget Adjustments Table ................................................................................................. 3

C – Budget Increases and Decreases Description ....................................................................... 4

1.3 – Object Classification (Schedule O) Obligations ................................................................ 6

D – Appropriations Language and Explanation of Changes ...................................................... 7

E – Legislative Proposals ............................................................................................................ 7

Section II – Annual Performance Plan and Report ................................................................... 8

A – Strategic Alignment ............................................................................................................. 8

B – Budget and Performance by Budget Activity .................................................................... 13

2.1.1 – BSA Administration and Analysis Resources and Measures ....................................... 13

BSA Administration and Analysis Budget and Performance ................................................... 13

C – Changes in Performance Measures .................................................................................... 14

Section III – Additional Information ........................................................................................ 14

A – Summary of Capital Investments ....................................................................................... 14

 
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Section I – Budget Request 

A – Mission Statement 

To safeguard the financial system from illicit use, combat money laundering and its related 

crimes including terrorism, and promote national security through the strategic use of financial 

authorities and the collection, analysis, and dissemination of financial intelligence. 

B – Summary of the Request 

The FY 2023 President’s Budget requests additional resources totaling $83,367,000 above 2021 

enacted, including for the implementation of the Fiscal Year (FY) 2021 Anti-Money Laundering 

Act/Corporate Transparency Act (AMLA/CTA) of the William M. (Mac) Thornberry National 

Defense Authorization Act (NDAA) and to increase staffing for the expansion of the Office of 

Chief Counsel. 

1.1 – Appropriations Detail Table 

1.2 – Budget Adjustments Table 

Dollars in Thousands 

 FTE Amount 

FY 2022 Annualized CR 285 $126,963 

Changes to Base: 

Maintaining Current Levels (MCLs): 0 $5,401 

Pay Annualization (2.7% average pay raise) 0 $462 

Pay Raise (4.6% average pay raise) 0 $2,377 

Non-Pay 0 $2,562 

Other Adjustments: 10 $28,887 

Adjustment to Meet Operating Levels 10 $28,887 

Subtotal Changes to Base 10 $34,288 

FY 2023 Current Services 295 $161,251 

Program Changes: 

Program Increases: 125 $49,079 

AMLA/CTA Implementation 115 $46,359 

Increase Office of Chief Counsel Staff 10 $2,720 

FY 2023 President's Budget Request 420 $210,330 

Dollars in Thousands

Appropriated Resources

New Appropriated Resources FTE AMO UNT FTE AMO UNT FTE AMO UNT FTE AMO UNT

BSA Administration and Analysis 269 $126,963 285 $126,963 420 $210,330 47.4% 65.7%

Subtotal New Appropriated Resources 269 $126,963 285 $126,963 420 $210,330 47.4% 65.7%

O ther Resources

Reimbursable 2 $1,941 3 $3,500 3 $3,500 0.0% 0.0%

Recoveries from Prior Years 0 $2,337 0 $0 0 $0 NA NA

Unobligated Balances from Prior Years 0 $29,444 0 $19,704 0 $2,817 NA -85.7%

Transfers In/Out (TEOAF) 0 $6,728 0 $22,500 0 $6,250 NA -72.2%

Subtotal O ther Resources 2 $40,450 3 $45,704 3 $12,567 0.0% -72.5%

Total Budgetary Resources 271 167,413 288 $172,667 423 $222,897 46.9% 29.1%

FY 2021 FY 2022 FY 2023 FY 2022 to FY 2023

O perating Plan Annualized CR Request

FY 2021 Other Resources and Full-time Equivalents (FTE) reflect actuals. 

% Change
FinCEN - 4 

C – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ........................................................+$5,401,000 / +0 FTE 

Pay Annualization (2.7% average pay raise) +$462,000 / +0 FTE 

Funds are requested for annualization of the January 2022 2.7% average pay raise. 

Pay Raise (4.6% average pay raise) +$2,377,000/ +0 FTE 

Funds are requested for a 4.6% average pay raise in January 2023. 

Non-Pay +$2,562,000 / +0 FTE 

Funds are requested for non-labor expenses such as travel, contracts, rent, supplies, 

and equipment. 

Other Adjustments..........................................................................+$28,887,000 / +10 FTE 

Adjustment to Meet Operating Levels +$28,887,000 / +10 FTE 

Funds are requested to meet operating levels in FY 2023, which includes IT infrastructure 

expansion and enhancements to support beneficial ownership secure system operations and 

maintenance. 

Program Increases ...............................................................................+$49,079,000 / +125 FTE

AMLA/CTA Implementation +$46,359,000 / +115 FTE 

The enactment of the FY 2021 National Defense Authorization Act (NDAA) included significant 

reforms to the U.S. anti-money laundering and countering the financing of terrorism (AML/CFT) 

regime through the AMLA and the CTA. 

The AMLA/CTA seeks to strengthen, modernize, and streamline the existing AML/CFT regime 

by promoting innovation, regulatory reform, and industry engagement through forums, such as 

the Bank Secrecy Act Advisory Group (BSAAG) and FinCEN Exchange. The AMLA calls for 

FinCEN to work closely with our regulatory, national security, and law enforcement partners to 

identify risks and priorities and provide valuable feedback to our industry partners. 

Within the AMLA, the CTA establishes a framework for uniform beneficial ownership reporting 

requirements for many corporations, limited liability companies, and other similar entities 

formed or registered to do business in the United States. The CTA provides FinCEN with the 

authority to collect that information, store it in a secure system, and share it with authorized 

government authorities and financial institutions, subject to effective safeguards and controls. 

To that end, FinCEN will use this funding to develop and maintain an information technology 

system for the reporting of information on beneficial ownership, collecting and securing the data, 

and creating access protocols and hiring staff to support outreach, implementation, and audits to 

ensure compliance with CTA rules. The AMLA and the CTA together set forth approximately 40 

rulemaking or other requirements, including periodic Congressional reporting on implementation 

efforts, assessments, and findings. Some key requirements authorized under the act include: 

1. Establishing standards for the reporting of information on beneficial ownership, building an 

information technology system to collect and secure the data, and creating access protocols, 

and ensuring enforcement of and compliance with the new reporting requirements; 
FinCEN - 5 

2. Establishing national anti-money laundering and countering the financing of terrorism 

priorities, issuing regulations to implement those priorities and other related requirements, 

and ensuring enforcement of and compliance with the new requirements; 

3. Enhancing whistleblower provisions to provide for a robust whistleblower program and new 

anti-retaliation protections; 

4. Establishing an Office of Domestic Liaison; 

5. Establishing foreign financial intelligence liaisons located overseas; 

6. Reviewing and revising Currency Transaction Report (CTR) and Suspicious Activity Report 

(SAR) requirements, and other existing Bank Secrecy Act (BSA) regulations and guidance; 

7. Expanding BSA requirements and obligations to persons engaged in the trade of antiquities; 

8. Hosting a Financial Crimes Tech Symposium, and establishing two new BSAAG 

subcommittees to enhance public-private partnerships in the areas of innovation and 

technology as well as information security; 

9. Establishing a BSA Analytical Hub; 

10. Conducting a formal review of regulations and guidance implementing the BSA; 

11. Formalizing a pilot program to allow financial institutions to share SARs with their foreign 

branches, subsidiaries, and affiliates, and ensuring enforcement of and compliance with the 

new requirements; 

12. Establishing an ongoing, timely process to receive and evaluate requests from law 

enforcement to financial institutions to keep accounts open; and 

13. Establishing an annual Bank Secrecy Act training program for all Federal examiners in the 

United States. FinCEN is required to comply with this new AMLA requirement to augment 

and build upon FinCEN’s continued, decades-long involvement with the Federal Financial 

Institutions Examination Council (FFIEC) and AMLA/BSA training opportunities, as well as 

drafting and updating the public FFIEC AML/BSA Examination Manual. While FinCEN is 

leveraging this experience and its relationships with delegated examiners, additional 

resources will enable the bureau to comply with this AMLA requirement. 

Timely and effective AMLA and CTA implementation continues to be FinCEN’s top priority 

and presents significant complexity and resource challenges. We are working diligently with our 

industry partners and law enforcement and regulatory stakeholders to implement these numerous 

provisions to further the national security, financial integrity, and innovative strength of the 

United States and protect the American people. 

Increase Office of Chief Counsel Staff +$2,720,000 / +10 FTE 

The Office of Chief Counsel staff increase commensurate with FinCEN’s workload. 
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1.3 – Object Classification (Schedule O) Obligations 

Dollars in Thousands 

 FY 2021 FY 2022 FY 2023 

Object Classification 

Actual 

Obligations 

Estimated 

Obligations 

Estimated 

Obligations 

11.1 - Full-time permanent 36,687 40,545 64,939 

11.3 - Other than full-time permanent 190 150 150 

11.5 - Other personnel compensation 1,017 891 891 

11.8 - Special personal services payments 158 0 0 

11.9 - Personnel Compensation (Total) 38,052 41,586 65,980 

12.0 - Personnel benefits 12,751 13,862 21,993 

Total Personnel and Compensation Benefits $50,803 $55,448 $87,973 

21.0 - Travel and transportation of persons 18 319 1,339 

23.1 - Rental payments to GSA 4,849 4,239 4,431 

23.2 - Rental payments to others 61 32 567 

23.3 - Communications, utilities, and miscellaneous charges 2,920 3,056 3,433 

24.0 - Printing and reproduction 62 62 68 

25.1 - Advisory and assistance services 1,847 4,552 8,827 

25.2 - Other services from non-Federal sources 55,176 74,474 71,146 

25.3 - Other goods and services from Federal sources 12,328 14,142 20,945 

25.4 - Operation and maintenance of facilities 13 0 0 

25.6 - Medical care 151 0 0 

25.7 - Operation and maintenance of equipment 7,885 9,000 9,920 

26.0 - Supplies and materials 135 516 1,551 

31.0 - Equipment 8,382 4,010 10,419 

Total Non-Personnel $93,827 $114,402 $132,646 

Total Obligations $144,630 $169,850 $220,619 

 

Full-time Equivalents (FTE) 271 288 423 

* Amounts reflect obligations of annually appropriated resources, carryover balances, reimbursables, and transfers. 

** Includes TEOAF funding for Beneficial Ownership Secure System in the amounts of $6.73M in FY 2021, $22.5M in FY 2022 and

requesting $6.25M in FY 2023. 
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D – 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 of non-Federal and foreign government 

personnel to attend meetings and training concerned with 

domestic and foreign financial intelligence activities, law 

enforcement, and financial regulation; services authorized by 5 

U.S.C. 3109; not to exceed $45,000 for official reception and 

representation expenses; and for assistance to Federal law 

enforcement agencies, with or without reimbursement, 

$210,330,000 of which not to exceed $94,600,000 shall remain 

available until September 30, 2025 for information technology 

and to implement Division F of the William M. (Mac) 

Thornberry National Defense Authorization Act for Fiscal Year 

2021 (Public Law 116-283). 

Note.--A full-year 2022 appropriation for this account was not 

enacted at the time the budget was prepared; therefore, the budget 

assumes this account is operating under the Continuing 

Appropriations Act, 2022 (Division A of P.L. 117-43, as 

amended). The amounts included for 2022 reflect the annualized 

level provided by the continuing resolution. 

Changes to the 

appropriations language 

represent the additional 

amount for necessary 

expenses of the Financial 

Crimes Enforcement 

Network for the 

implementation of 

Division F of the William 

M. (Mac) Thornberry 

National Defense 

Authorization Act for 

Fiscal Year 2021 (Public 

Law 116-283), and for 

expansion of the Office 

of Chief Counsel. 

E – Legislative Proposals 

FinCEN has no legislative proposals. 
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Section II – Annual Performance Plan and Report 

A – Strategic Alignment 

Most notably, FinCEN’s work supports Treasury’s Strategic Objective 2.2: Economic Measures 

to Advance National Security which seeks to enhance and protect national security through the 

application of targeted financial measures and review of certain foreign investments; and 

Strategic Objective 2.4: Transparency in the Financial System which seeks to increase 

transparency in the domestic and international financial system. 

Since the start of FY 2021, FinCEN had several noteworthy accomplishments highlighted below: 

Implementation of the Anti-Money Laundering Act of 2020 (AMLA) and its Corporate 

Transparency Act (CTA): 

As mentioned above, the AMLA/CTA sets the stage for a reassessment and expansion of the 

U.S. AML framework. Chief among the requirements of the AMLA are those related to the 

CTA, which require FinCEN to implement beneficial ownership reporting requirements for 

many corporations, LLCs, and other similar legal entities. 

In addition to the CTA, FinCEN is tasked with an extensive and resource intensive list of 

requirements all aimed at improving and enhancing the existing AML/CFT framework and 

expanding FinCEN’s role in innovation, regulatory reform, and industry engagement pertaining 

to the administration of the BSA. The AMLA requirements include several significant 

rulemakings, numerous Congressional reports and assessments, and specific programs that 

authorize significant resource allocations, to include hiring and supporting domestic liaison 

officers across the United States and foreign financial intelligence unit liaisons abroad, staffing a 

whistleblower program, appointing additional officers addressing innovation and information 

security, creating new subcommittees of the Bank Secrecy Act Advisory Group, etc. 

Regulatory Actions: 

AML/CFT Priorities (AMLA Section 6101): In June 2020, FinCEN published the first 

government-wide AML/CFT priorities which identify the most significant threats facing the 

United States, including: corruption, cybercrime, domestic and international terrorist financing, 

fraud, transnational criminal organizations, drug trafficking organizations, human trafficking and 

human smuggling, and proliferation financing. FinCEN also published two statements to provide 

guidance to covered institutions on how to approach these priorities. FinCEN will be publishing 

a notice of proposed rulemaking (NPRM) in 2022 to implement these priorities and make other 

amendments to financial institutions’ AML program rules. 

Arts and Antiquities (AMLA Section 6110): FinCEN published a notice in March 2021 to inform 

financial institutions about (1) the AMLA efforts related to trade in antiquities and art, (2) select 

sources of information about existing illicit activity related to antiquities and art, and (3) provide 

specific instructions for filing SARs related to trade in antiquities. FinCEN then published an 

advance notice of proposed rulemaking (ANPRM) related to trade in antiquities in September 

2021 seeking public comment on the proposed rules. FinCEN received over 30 comments to the 

ANPRM and is currently reviewing them to determine next steps and the content of a notice of 

proposed rulemaking that it will issue at a later date. 
FinCEN - 9 

CTA / Beneficial Ownership (AMLA Sections 6401-6403): FinCEN published an advance notice 

of proposed rulemaking in April 2021 seeking public comment on the implementation of 

beneficial ownership information reporting provisions of the CTA. FinCEN published a NPRM 

in December 2021 seeking public comment on the proposed rules focusing on who must report 

beneficial ownership information, when they must report, and what information they must 

provide. FinCEN received nearly 250 comments to the reporting NPRM and is currently 

reviewing them as it considers the issuance of a final regulation implementing the beneficial 

ownership information reporting requirements. FinCEN anticipates publishing later this year 

proposed rules on beneficial ownership information access and disclosure requirements as the 

next step in the CTA rulemaking series, as well as finalizing the rules on reporting beneficial 

ownership information.

SAR Sharing Pilot Program (AMLA Act 6212): FinCEN published an NPRM in January 2022, 

seeking public comment on the establishment of a limited-duration pilot program for sharing 

SARs. The pilot program would permit a financial institution with a SAR reporting obligation to 

share SARs and information related to SARs with the institution’s foreign branches, subsidiaries, 

and affiliates for the purpose of combating illicit finance risks. The proposed rule ensures the 

sharing of information process is subject to appropriate data security and personal confidentiality 

standards and limited by federal and state requirements. Comments to the proposed rule are due 

by March 28, 2022. Following receipt and review of those comments, FinCEN will begin the 

process of drafting a final rule to implement this section. 

Review of Regulations and Guidance (AMLA Section 6216): In December 2021, FinCEN 

published a request for information (RFI) seeking public comments on ways to streamline, 

modernize, and update the AML/CFT regime of the United States, including ways to modernize 

risk-based AML/CFT regulations and guidance to protect U.S. national security in a costeffective and efficient manner. FinCEN received nearly 140 comments to the RFI in February 

2022. FinCEN will review the comments to determine how best to incorporate the proposals into 

modernizing the AML/CFT regulations and guidance. 

Bank Secrecy Act Advisory Group (BSAAG) Subcommittees (AMLA Section 6207 and 

6302):

FinCEN created and is administering two new BSAAG Subcommittees: Innovation and 

Technology, and Information Security and Confidentiality, as required under AMLA Sections 

6207 and 6302, respectively. 

SAR Trends Analyses (AMLA Section 6206):

FinCEN published a Financial Trend Analysis on ransomware in October 2021 and another on 

environmental crimes in December 2021. FinCEN will publish additional Trend Analysis 

products on significant money laundering issues in FY 2023 as required by the AMLA. 

Enforcement and Compliance: 

From January 2021 to the present, FinCEN’s Enforcement and Compliance Division (ECD) 

implemented an Office of the Whistleblower and an interim whistleblower program to 

implement Section 6314 of the AMLA. From January through June 2021, ECD conducted an 
FinCEN - 10 

analysis of the viability of a No-Action Letter process at FinCEN, and drafted and submitted a 

report on June 28, 2021, to Congress on the same per Section 6305 of the AMLA. 

ECD designed policies and procedures to process and track “keep open” requests and engaged in 

extensive research and consultations with other financial regulators to begin implementation of 

the annual training programs requirement for BSA regulators. 

Modernize, Streamline, and Simplify Regulatory Authorities: 

In addition to the AMLA/CTA rulemakings, FinCEN made significant progress with respect to 

advancing regulatory initiatives impacting the AML framework this year, including BSA 

reporting requirements relating to the Paycheck Protection Program (PPP). 

 FinCEN issued a final rule to require customer identification program, AML program, and 

beneficial ownership requirements for banks lacking a federal functional regulator. 

 FinCEN issued NPRMs related to virtual currency and funds transmittal recordkeeping 

requirements. 

 Administrative Rulings: Closed 92 administrative ruling cases in FY 2021. 

 Pilots: FinCEN continues to discuss potential pilot programs with U.S. financial institutions 

and established one in FY 2021 to enable the more efficient sharing of SARs in a certain 

context.

 Real Estate ANPRM: In December 2021, FinCEN issued an ANPRM seeking public 

comment on potential rulemaking to create a recordkeeping and reporting requirements 

concerning certain all-cash real estate purchases. FinCEN is reviewing the nearly 150 

comments it received on the ANPRM and intends to prepare an NPRM for publication later 

this year. 

 Geographic Targeting Order (GTO) Regulation: On November 15, 2021, FinCEN issued a 

final rule modernizing the regulation implementing the GTO authority, which had not been 

updated despite several successive amendments to the statute. 

Guidance to Industry:

 During fiscal year 2021, FinCEN worked closely with federal and state banking agencies to 

update the Federal Financial Institutions Examination Council (FFIEC) BSA/AML 

Examination Manual. In total, 12 sections of the manual were updated. 

 FinCEN issued nine advisories and notices, including a ransomware advisory, charities fact 

sheet, and several addressing COVID-19-related fraud. 

 FinCEN published a number of public documents either jointly or in consultation with the 

FBAs, including a Joint Statement issued by the Board of Governors of the Federal Reserve 

System, the Federal Deposit Insurance Corporation, and the Office of the Comptroller of the 

Currency, in consultation with FinCEN and the National Credit Union Administration, 

regarding Model Risk Management for Bank Systems Supporting Bank Secrecy Act/AntiMoney Laundering Compliance (April 9, 2021). 

 FinCEN issued a new Fact Sheet in December 2020 providing clarification on FinCEN’s 

information sharing program under Section 314(b) of the USA PATRIOT Act. 

 FinCEN’s Regulatory Support Section responded to over 13,500 incoming inquiries from 

industry and other stakeholders in FY 2021. 

 
FinCEN - 11 

BSA Enforcement and Supervision:

 FinCEN finalized four public civil enforcement actions in response to serious violations of 

the BSA, which resulted in the assessment of civil money penalties pursuant to 31 U.S.C. § 

5321 totaling, in the aggregate, $690,000,000.1

 FinCEN finalized more than 275 compliance matters. 

 Led or participated in two examinations of non-bank financial institutions and one depository 

institution. While FinCEN has delegated its examination authority under 31 CFR 1010.810, 

FinCEN may still conduct compliance examinations should a specific need arise and its 

limited staffing and resources allow. These examinations were targeted, limited-scope 

examinations based on leads specific to FinCEN priorities. 

 Conducted a FinCEN examination of compliance with a Geographic Targeting Order (GTO) 

at a title insurance company, including the development of attendant policies and procedures. 

Public-Private Engagement: 

 FinCEN continued to support the BSAAG AML Effectiveness Working Group and held 

several FinCEN Exchange events to facilitate information sharing among law enforcement, 

national security agencies, financial institutions and other private sector entities, and 

FinCEN, including relating to key issues like ransomware (November 2020 and August 

2021) and environmental crime (November 2021). 

 FinCEN continued to enhance and effectively execute its Rapid Response Program (RRP), 

which assists law enforcement in the recovery of funds stolen from U.S. victims of cyberenabled fraud schemes. The RRP has been used to confront cyber threats involving 

approximately 70 foreign jurisdictions and since its inception in 2015 has successfully 

assisted in the recovery of over $1.1 billion. From October 1, 2020 through January 31, 

2022, the RRP received 1,057 requests from law enforcement with a total value of 

approximately $378 million, of which the RRP assisted in recovering approximately $183 

million for U.S. victims (48% of the value reportedly stolen).2

 

 FinCEN hosted Innovation Hours meetings with Financial Technology, Regulatory 

Technology, and other firms creating innovative solutions to AML/CFT challenges, which 

FinCEN is using to enhance our national security through the promotion of responsible 

financial services innovation that furthers the purposes of the Bank Secrecy Act (BSA). 

Enhance Systems and Analytical Capabilities:

 Deployed new search capabilities targeted at transaction data and visualization capabilities 

on BSA reports information and transaction data. 

Expand Special Collections Efforts:

 During 2021, FinCEN twice re-issued GTOs that require U.S. title insurance companies to 

obtain beneficial ownership information for persons using shell companies that are involved 

in residential real estate transactions in twelve geographic areas. 

1

 For additional information, please see the Enforcement Actions posted on https://www.fincen.gov/newsroom/enforcement-actions 

2

 https://www.fincen.gov/sites/default/files/shared/RRP%20Fact%20Sheet%20Notice%20FINAL%20508.pdf 
FinCEN - 12 

 FinCEN also prepared, researched and issued nine new special collection requests and one 

renewal (demand letters, foreign financial agency regulations, and/or geographic targeting 

orders) on major illicit finance issues around the world. 

Financial Intelligence:

 FinCEN’s ongoing intelligence activities included at least 90 specific products for law 

enforcement, industry, and other partners. 

International Engagement and Information Sharing: 

 FinCEN actively engages in the work of the Egmont Group of Financial Intelligence Units 

(FIUs) and supports its analytical and operational activities. As the U.S. FIU, FinCEN 

engages in extensive information exchange of financial intelligence on behalf of itself and 

U.S. law enforcement with FIUs that are members of the Egmont Group, as appropriate. 

From October 1, 2020 through January 31, 2022, FinCEN received more than 1,400 

information requests from partner FIUs and provided more than 1,400 responses. FinCEN 

received more than 1,500 spontaneous information disclosures from partner FIUs and 

provided nearly 1,000 such disclosures to partner FIUs. In addition, FinCEN sent more than 

1,000 information requests to partner FIUs. 

FinCEN’s FY 2022 and FY 2023 Priorities include: 

 Continuing to effectively implement the AMLA/CTA, including: 1) the design and 

development of the beneficial ownership information technology system, 2) the statutorily 

mandated beneficial ownership rulemakings under the CTA, and 3) approximately 40 

additional regulatory and other requirements under the AMLA, to include additional 

rulemakings, assessments, and guidance documents; periodic Congressional reporting; and 

numerous other provisions requiring coordination, collaboration with and feedback to law 

enforcement and financial institutions, among other things. FinCEN seeks the resources for 

the personnel and technology needed to meet these significant and impactful statutory 

requirements. 

 Updating FinCEN’s mission and priorities in the context of a post-pandemic economic 

recovery, AMLA/CTA implementation, and interference from foreign state actors. This 

includes an emphasis on advancing the innovative strength of the U.S. financial system, 

financial inclusion, and countering abuse by malign state actors and domestic terrorists, as 

well as corporate and political corruption that undermine the integrity and opportunity of the 

financial system, beyond the prior, post-9/11 emphasis on foreign terrorists. 

 Continuing to develop cyber-related expertise and capacity to address cyber-related finance 

threats, including the rising threat of ransomware and other criminal activity. 
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B – Budget and Performance by Budget Activity 

2.1.1 – BSA Administration and Analysis Resources and Measures 

Dollars in Thousands FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 FY 2023 

 Resource Level Actual Actual Actual Actual Actual Annualized 

CR Request 

Appropriated Resources $115,003 $115,003 $117,800 $126,000 $126,963 $126,963 $210,330 

Reimbursable Resources $2,526 $2,198 $1,771 $3,000 $1,941 $3,500 $3,500 

TEOAF 0 0 0 0 $6,728 $22,500 $6,250 

Budget Activity Total $117,529 $117,201 $119,571 $129,000 $135,632 $152,963 $220,080 

Full-time Equivalents (FTE) 275 281 273 265 271 288 423 

Workload Output/Activity FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2021 FY 2022 FY 2023 

Actual Actual Actual Actual Actual Estimate Estimate Estimate 

Number of SARs filed 2,401,896 2,537,225 2,698,841 3,039,421 3,524,610 2,863,200 3,595,102 3,667,004 

Number of total BSA reports 

filed 19,322,891 20,393,947 20,755,285 20,051,834 23,036,995 21,593,799 23,497,735 23,967,690 

Number of BSA users 11,452 11,739 12,801 13,047 13,260 13,581 13,525 13,796 

Performance Measure FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2021 FY 2022 FY 2023 

Actual Actual Actual Actual Actual Target Target Target 

Percentage of Domestic Law 

Enforcement and Foreign 

FIUs who Assert Analytic 

Products Used Led to 

Detection and Deterrence of 

Illicit Activity 

92% 95% 92% 97% 96% 90% DISC DISC 

Percentage of Domestic Law 

Enforcement and Regulators 

Who Assert Queried BSA 

Data Led to Detection and 

Deterrence of Illicit Activity 

86% 85% 92% 90% 93% 89% 90% 90% 

Percentage of Users Satisfied 

with FinCEN Information 

Sharing Systems 

87% 86% 89% 88% 87% 87% 85% 85% 

Key: DISC - Discontinued

BSA Administration and Analysis Budget and Performance 

($210,330,000 from direct appropriations, $6,250,000 from TEOAF Strategic Support, 

$3,500,000 from reimbursable sources): 

FinCEN is a bureau of the U.S. Department of the Treasury. The Director of FinCEN reports to 

the Under Secretary for the Office of Terrorism and Financial Intelligence (TFI). FinCEN serves 

two primary roles in the financial regulatory and anti-money laundering framework: 1) 

administrator and primary regulator of the BSA; and 2) FIU for the United States. In carrying 

out its mission, FinCEN has numerous statutory areas of responsibility: 

 Developing and issuing regulations under the BSA, including the regulatory requirements of 

the AMLA/CTA which are codified as part of the BSA; 

 Enforcing compliance with the BSA, at times in partnership with law enforcement and other 

regulatory partners; 

 Maintaining a network of information sharing with FIUs in 166 partner countries that are part 

of the Egmont Group of FIUs; 

 Receiving millions of new financial reports each year; 

 Securing and maintaining the BSA database, with over 300 million reports; 
FinCEN - 14 

 Analyzing and disseminating financial intelligence to federal, state, and local law 

enforcement, federal and state regulators, foreign FIUs, and industry; and 

 Promoting authorized information sharing and coordination among law enforcement, FIUs, 

regulatory partners, and industry. 

Description of Performance: 

FinCEN conducts four annual surveys of the BSA user-facing systems, information sharing 

tools, and to assess the value of FinCEN’s data and analysis. The results provide valuable 

feedback on FinCEN’s performance safeguarding the financial system from illicit use, 

combatting money laundering, and promoting national security. 

Additionally, FinCEN monitors the percentage of domestic law enforcement and regulators who 

assert that queried BSA data led to the detection and deterrence of illicit activity. The survey 

looks at the value of FinCEN 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; 

or provided information for an investigative or examination report. 

The final performance measure is based on survey responses and represents user satisfaction 

with the BSA E-Filing System, FinCEN Query, and the Egmont Secure Web (ESW). Starting 

with industry, FinCEN collects and maintains BSA reports filed by financial institutions and 

other filers. In turn, FinCEN provides authorized users that include, where appropriate, 

Treasury’s Office of Terrorism and Financial Intelligence TFI) access to a query system 

containing 16 years of BSA data. FinCEN also provides foreign FIUs in the Egmont Group with 

a secure system for exchanging financial intelligence to combat money laundering and terrorist 

financing. 

 

C – Changes in Performance Measures 

With the publication of Treasury’s Strategic Plan for FY 2022-2026, FinCEN will work this year 

to baseline performance against the new strategic objectives. This could result in changes to 

performance measures in the FY 2024 budget. 

Performance Measure or Indicator Proposed Change and Justification

Percentage of Domestic Law 

Enforcement and Foreign FIUs who 

Assert that they Used Analytic Products 

that Led to Detection and Deterrence of 

Illicit Activity 

Discontinue. FinCEN is discontinuing this 

performance measure and is working to 

develop an improved replacement measure to 

assess performance. 

Section III – Additional Information 

A – Summary of Capital Investments 

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

under BSA requirements, which totaled more than 23 million filings in FY 2021. To successfully 

fulfill its mission, FinCEN relies on secure, advanced IT to manage the collection, processing, 
FinCEN - 15 

storage, analysis, and dissemination of BSA information that contributes to the strength of and 

confidence in the U.S. financial system. On January 1, 2021, Congress passed the National 

Defense Authorization Act (NDAA), which includes the Corporate Transparency Act (CTA). 

The CTA dictates that many companies disclose beneficial ownership information to FinCEN. 

As a result, FinCEN, has expanded its IT investment portfolio to include the resources necessary 

to securely collect, process, store, and disseminate beneficial ownership information. 

 

FinCEN’s IT strategy already takes into account the growing need for financial institutions to 

meet obligations as efficiently as possible, while ensuring that FinCEN and law enforcement 

agencies receive accurate, timely, and reliable BSA and beneficial ownership information to 

track money trails, identify money laundering, and unravel terrorist financing networks. 

FinCEN’s IT strategy also focuses on the critical need to improve the quality and accessibility of 

its data and increase responsiveness to stakeholders by maintaining and building upon flexible 

and innovative technical solutions. FinCEN’s FY 2023 request include an increase in its IT 

portfolio by approximately $29M annually, to support FinCEN’s current mission architecture 

and continue the development support and maintenance for the beneficial ownership 

requirements of the CTA. This increase is required to fully fund FinCEN’s mission IT platform, 

which is the foundational architecture for the CTA beneficial ownership system. FinCEN’s 

initial development costs includes obligations from TEOAF Strategic Support in FY 2021 ($6.73 

million), FY 2022 ($22.5 million), and FY 2023 ($6.25 million). 

A summary of capital investments, including major information technology and non-technology 

investments, can be accessed at: 

https://www.treasury.gov/about/budget-performance/Pages/summary-of-capitalinvestments.aspx.