Financial Crimes Enforcement Network 

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 2007 FY 2008 FY 2009

Salaries and Expenses Enacted Enacted Request $ Change % Change 

BSA Administration and Analysis $64,780 $76,889 $82,157 $5,268 6.85%

Regulatory Support Programs 8,436 8,955 9,178 223 2.49%

Total Appropriated Resources $73,216 $85,844 $91,335 $5,491 6.40%

Total FTE 326 334 343 9 2.69%

FY 2009 Priorities 

• Improve regulatory effectiveness by ensuring consistent application of Bank Secrecy 

Act (BSA) regulations through implementation of memoranda of understanding 

allowing information sharing between FinCEN and additional state regulators and 

enhanced communication and clarification of regulatory requirements to financial 

industries; 

• Strengthen effectiveness of international anti-money laundering and counter-terrorist 

financing efforts and combat foreign threats by improving analytical products and 

responsiveness to foreign government counterparts; and 

• Ensure the safety and security of FinCEN’s employees and property through the 

implementation of additional physical security measures. 
Table of Contents 

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

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

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

Section 2 – Budget Adjustments and Appropriation Language................................... 6

2.1 – Budget Adjustments Table..................................................................................... 6 

2A – Budget Increases and Decreases Description ........................................................ 6 

2.2 – Operating Levels Table.......................................................................................... 9 

2.3 – Appropriations Detail Table ................................................................................ 10 

2B – Appropriations Language and Explanation of Changes....................................... 10 

2C – Legislative Proposals ........................................................................................... 10 

Section 3 – Budget and Performance Plan ................................................................... 11

3.1 – Budget by Strategic Outcome .............................................................................. 11 

3A – BSA Administration and Analysis...................................................................... 12 

3.2.1 – BSA Administration and Analysis Budget and Performance Plan.................. 12 

3B – Regulatory Support Programs.............................................................................. 15 

3.2.2 – Regulatory Support Programs Budget and Performance Plan.......................... 15 

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

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

4.1 – Summary of IT Resources Table ......................................................................... 20 

4B – Information Technology Strategy ........................................................................ 21 

4.2 – PART Evaluation Table....................................................................................... 23 
 Section 1 – Purpose

1A – Description of Bureau Vision and Priorities 

The Financial Crimes Enforcement Network (FinCEN), a bureau within Treasury’s 

Office of Terrorism and Financial Intelligence, ensures safer and more transparent U.S.

and international financial systems through the administration of the Bank Secrecy Act 

(BSA), in support of the Department of the Treasury’s strategic goal “Prevented 

Terrorism and Promoted the Nation’s Security through Strengthened International 

Financial Systems.” 

The BSA requires financial institutions to file reports on certain types of financial activity 

and to establish appropriate internal controls to guard against money laundering, terrorist 

financing, and other types of illicit finance. These reports have a high degree of 

usefulness in criminal, tax, and regulatory matters as well as counter-terrorist financing. 

The documents filed by businesses pursuant to the BSA requirements are heavily used by 

law enforcement agencies, both domestically and through exchanges with international 

counterparts to identify, detect and deter money laundering whether it is in furtherance of 

a criminal enterprise, terrorism, tax evasion or other unlawful activity. FinCEN also 

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

center set up to collect, analyze, disseminate, and exchange information pursuant to a 

country’s anti-money laundering/counter-terrorist financing legislation and regulations. 

This includes information about suspicious or unusual financial activity reported by the 

finanical sector. 

FinCEN is in the process of updating its strategic plan for FY 2008 – FY 2012 to align 

with the new Treasury Department strategic plan. The bureau’s priorities are linked to 

the following strategic goals proposed in the revised plan: 

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

financial supporters, and other perpetrators of financial crime; 

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

activity; and

• Enhanced management, use, and security of BSA information. 

The total resources required to support FinCEN for FY 2009 are $96,586,000 including 

$91,335,000 for direct appropriation and $5,251,000 from offsetting collections. 

1B – Program History and Future Outlook 

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

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

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

information. 

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

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

FinCEN - 1 
regulated financial institutions and providing feedback enabling greater clarity regarding 

regulatory expectations and optimized understanding of the value of their contributions. 

FinCEN’s regulatory policy protects the financial system and enhances national security 

by making relevant data available to law enforcement authorities and the regulatory 

agencies that examine for BSA compliance, and maximizes the effectiveness and 

efficient use of government resources. 

Specific FY 2007 accomplishments in the regulatory area include: 

• Published the following final and amended BSA regulations: Amendment to the Bank 

Secrecy Act Regulations-Imposition of Special Measure Against Banco Delta Asia, 

Including Its Subsidiaries Delta Asia Credit Limited and Delta Insurance Limited, as a 

Financial Institution of Primary Money Laundering Concern (March 2007); 

Amendments to the Bank Secrecy Act Regulations Regarding Casino Recordkeeping 

and Reporting Requirements (June 2007); Anti-Money Laundering Programs-Special 

Due Diligence Programs for Certain Foreign Accounts (August 2007); 

• Published additional BSA guidance to financial institutions to improve consistency in 

the interpretation and application of BSA regulations, and reduce misperception of 

excessive regulatory expectations. Specific guidance included: Guidance (Frequently 

Asked Questions) – Suspicious Activity Reporting Requirements for Mutual Funds 

(October 2006); Advisory – Potential Money Laundering Risks related to Shell 

Companies (November 2006); Guidance (Frequently Asked Questions) – Customer 

Identification Programs and Banks Serving as Insurance Agents (December 2006); 

Guidance – Application of the Customer Identification Program Rule to Future 

Commission Merchants Operating as Executing and Clearing Brokers in Give-Up 

Arrangements (April 2007); Guidance – Requests by Law Enforcement for Financial 

Institutions to Maintain Accounts (June 2007); Guidance – Suspicious Activity Report 

Supporting Documentation (June 2007); 

• Delivered complex analytical studies targeted to regulatory authorities from each of 

the 43 state regulators with which FinCEN has entered into a memoranda of 

understanding to exchange information; 

• Developed and provided reports on mortgage loan fraud, money laundering through 

the commercial real estate sector, and shell companies to assist in the promulgation of 

guidance to financial institutions and regulatory examiners about vulnerabilities and 

associated compliance obligations; 

• Participated as a speaker/panelist in 99 domestic and overseas outreach events; 

• Enhanced outreach activities to the money services business (MSB) industry by using 

information from law enforcement partners that encounter potential unregistered 

MSBs to focus FinCEN’s education initiatives; 

• Translated MSB brochures into seven languages; 

• Developed a strategy in conjunction with the Internal Revenue Service (IRS) to focus 

resources for ensuring BSA compliance by non-bank financial institutions; 

• Implemented an action plan to address concerns among domestic and international 

policymakers, law enforcement, and financial institutions about the misuse of various 

types of business entities (e.g., corporations, limited liability companies, limited 

partnerships, trusts, etc.) to facilitate money laundering and other financial crimes; 

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• Assessed civil money penalties against financial institutions for willful violations of

BSA requirements, including through joint or concurrent actions with federal and state 

agencies; and 

• Contributed to the revisions of the Federal Financial Institutions Examination Council 

(FFIEC) BSA/AML examination manual, which helps ensure consistent application 

by federal and state supervisors of their regulatory authority. 

In FY 2008/2009, FinCEN will expand regulatory policy efforts to include: 

• Implementing additional information sharing agreements with federal and state 

regulators, with a focus on insurance commissioners; 

• Identifying compliance trends and patterns across industries subject to the BSA and 

publishing, as appropriate, studies promoting greater awareness of emerging money 

laundering trends and vulnerabilities; 

• Continuing efforts to overhaul BSA regulations for inclusion in a new Code of Federal 

Regulations chapter to provide greater clarity in regulations and make them easier for 

industry to follow, as well as more intuitive and responsive to industry feedback; 

• Publishing final and amended BSA regulations for the anti-money laundering program

rule for dealers in precious metals, precious stones, or jewels; 

• Continuing efforts to implement and refine strategies with regard to the MSB industry, 

including partnerships to identify unregistered MSBs, consider options to simplify and 

clarify the regulatory framework, and continue to enhance outreach activities 

concerning this industry; 

• Continuing efforts, in conjunction with the federal banking agencies, to match riskbased examination for BSA compliance with actual risks posed by products and 

services offered, and customers and geographic locations served by depository 

institutions; 

• Undertaking enforcement actions against financial institutions, as necessary, for 

willful violations of BSA requirements, including joint or concurrent actions with 

federal and state agencies; 

• Reducing any undue perception of excessive regulatory responsibilities by providing 

clarification to regulated industries regarding their programmatic, recordkeeping, and 

reporting requirements under the BSA; 

• Increasing efforts to provide regulatory partners with analytical products and 

information to identify institutions with potential compliance problems, thereby 

promoting enhanced consistency across examinations; 

• Reducing the time to coordinate and complete compliance reviews with regulatory 

examination authorities, while promoting speedy remediation by industry of identified 

deficiencies; and 

• Streamlining regulatory requirements and other modifications relating to MSBs, 

subsequent to a review of the existing regulatory framework and current issues. 

FinCEN’s analytic efforts focus on developing products and services that help law 

enforcement better utilize resources to enhance detection and deterrence of domestic and 

international money laundering, terrorist financing, and other illicit activity. This 

includes exchange of information with counterpart foreign government FIUs in over 100 

countries that are members of the Egmont Group. 

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Specific FY 2007 accomplishments related to analytic efforts include: 

• Enhanced support to law enforcement agencies by focusing on actionable analyses 

targeted at high-priority money laundering and terrorist financing targets; 

• Collaborated on analytical projects with key federal law enforcement customers, such 

as the FBI’s Terrorist Financing Operations Section, the Drug Enforcement 

Administration, Customs and Border Protection’s Tactical Analysis Group, 

Immigration and Customs Enforcement’s Financial and Trade Division, and other 

analytical agencies like the National Drug Intelligence Center; 

• Published a technical reference guide for law enforcement officials on MSBs to 

describe traditional types of remittances and services, as well as emerging services 

such as online payments and prepaid card services; 

• Collaborated with other FIUs in the Egmont Group to improve understanding of how 

emerging payments methods, such as internet-based payment methods, might be 

exploited for illicit activity; 

• Completed collaborative efforts with other FIUs, law enforcement agencies, and the 

intelligence community to take full advantage of financial intelligence sources and 

resources; 

• Worked with Egmont Group partners to develop actionable intelligence concerning 

illicit money flows across the northern and southwestern borders of the U.S.; 

• Provided greater and more sustained technical assistance and training to Egmont 

Group candidates under FinCEN’s sponsorship and to Egmont members whose 

organizational capabilities have been strained by growing needs to collect and analyze 

financial intelligence and building the information technology infrastructure for these 

activities; and 

• Supported the establishment of a permanent Egmont Group Secretariat with the 

appointment of the Executive Secretary and opening of a permanent office in Toronto 

July 3, 2007. 

In FY 2008/2009, FinCEN will continue to develop analytic products and services that 

enhance detection and deterrence of illicit activity. These efforts include: 

• Continuing the proactive evaluation, analysis and referral of potential terrorism and 

financial crimes related SARs to the law enforcement and intelligence communities; 

• Expanding capabilities and methodologies for geographic and industry threat 

assessments and for financial analysis; 

• Enhancing the focus on transnational financial crimes, to include cross-border money 

flows, the South Florida region, and an annual threat/targeting assessment of the 

Southwest Border; 

• Expanding the complexity of FinCEN products to better meet the needs of the 

bureau’s international partners, and increasing U.S. law enforcement use of the 

Egmont FIU process to combat money laundering and terrorist financing; 

• Continuing outreach to U.S. law enforcement and regulatory agencies to educate them 

on the benefits provided by the global network of FIUs in terms of investigative and 

intelligence resources and information sharing;

• Increasing the number of analyst exchanges with partner FIUs, and expanding 

customized technical assistance and training provided to meet the needs of specific 

FIUs in vulnerable international geographic areas; and 

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• Continuing to publish technical reference manuals for law enforcement officials 

describing investigational approaches to payment systems. 

FinCEN’s efforts related to the management, use, and security of BSA information focus 

on maximizing utilization by improving the overall information infrastructure and 

enhancing information technology management capabilities. 

Specific FY 2007 accomplishments related to the management, use, and security of BSA 

information include: 

• Expanded access to BSA information to enable authorized law enforcement and 

regulatory users to quickly and efficiently query the data when needed; 

• Conducted a feasibility analysis with the financial services industry and law 

enforcement to determine the benefits and costs to all affected parties as a part of a 

Congressionally mandated study of the feasibility of implementing a cross-border 

electronic funds transfer reporting requirement; 

• Established a formal Data Issue Management process and framework and Data 

Management Council, including representatives from FinCEN and the IRS, to address 

BSA data quality issues in a consistent and repeatable fashion; 

• Maintained the focus on promoting electronic filing of BSA reports as a way to 

enhance speed, economy, and data quality; 

• Deployed disaster recovery capability for the BSA E-Filing system to ensure 

continuity of system operations for stakeholders in the event of a major outage; 

• Launched FinCEN’s first enterprise-wide business transformation and IT

modernization program, based on an effective collaboration of BSA stakeholders and 

a rigorous program management framework; and 

• Established a new Program Management Office (PMO), which will create a 

disciplined environment in which proven project management principles, tools, and 

techniques will be consistently applied across the bureau’s major information 

technology initiatives to identify, manage, and mitigate risks. 

In FY 2008/2009, FinCEN will accelerate efforts related to the management, use, and 

security of BSA information to include: 

• Continuing deployment of a disaster recovery capability for critical systems to 

minimize or eliminate system downtime in the event of the loss of access or system

use at FinCEN’s primary location; 

• Pending final approval by the Secretary of the Treasury, beginning development of the 

technological systems required to receive, securely store, analyze and disseminate 

cross-border wire transfer data; 

• Enhancing project management capabilities and oversight of information technology 

projects by expanding Capital Investment Planning, Enterprise Architecture, 

Configuration Management, and Change Management controls; 

• Beginning to upgrade various technology components to meet the expanded user 

population, and increase electronic filing alternatives; and 

• Continuing planning efforts and establishing the foundation for future BSA data 

management and quality activities. 

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Section 2 – Budget Adjustments and Appropriation Language 

2.1 – Budget Adjustments Table 

Dollars in Thousands

Salaries and Expenses FTE Amount

FY 2008 Enacted 334 $85,844

Maintaining Current Levels (MCLs):

 Pay Annualization 300

 Pay Inflation Adjustment 861

 Non-Pay Inflation Adjustment 981

Initiative Annualization:

 Annualization of Project Management Initiative 6 1,337

Transfers In:

 Transfer from IRS for BSA E-Filing 1,000

Total FY 2009 Base 340 $90,323

Program Decreases:

 Reprioritization of Resources (4) (697)

 Information Technology Funding Realignment (3,449)

Program Reinvestment:

 BSA Data Management and Analysis 2,897

Program Increases:

 Improve BSA Effectiveness/Consistency 5 1,139

 Strengthen Global Anti-Money Laundering Efforts 2 865

 Increase Physical Security 257

Subtotal FY 2009 Program Changes 3 1,012

Total FY 2009 President's Budget Request 343 $91,335

2A – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ...........................................+$2,142,000 / +0 FTE 

Pay Annualization +$300,000 / +0 FTE 

Funds are requested for the FY 2009 cost of the January 2008 pay raise. 

Pay Inflation Adjustment +$861,000 / +0 FTE 

Funds are requested for the proposed January 2009 pay raise. 

Non-Pay Inflation Adjustment +$981,000 / +0 FTE 

Funds are requested for non-labor related items such as contracts, travel, supplies, 

equipment, and GSA rent adjustments. 

Initiative Annualization .................................................................+$1,337,000 / +6 FTE 

Annualization of Project Management Initiative +$1,337,000 / +6 FTE 

These funds will allow FinCEN to complete implementation of the Project Management 

Office (PMO) approved in FY 2008. This annualization provides the remaining funding 

for OMB, Treasury and GAO recognized requirements to improve FinCEN's project 

management capability for both information technology and non-information technology 

projects, which are especially critical at this time of modernization of FinCEN's core IT 

systems and functions. 

Transfers In ....................................................................................+$1,000,000 / +0 FTE 

Transfer from IRS for BSA E-Filing +$1,000,000 / +0 FTE 

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The IRS annually reimburses FinCEN for the cost associated with operations and 

maintenance contract supporting the Bank Secrecy Act (BSA) e-filing system which is 

administered and controlled by FinCEN. This transfer will provide FinCEN with the 

base funding it needs to continue supporting its BSA e-filing system. 

Program Decreases ..........................................................................-$4,146,000 / -4 FTE 

Reprioritization of Resources -$697,000 / -4 FTE 

Base reductions were identified as the result of business process efficiencies from

consolidation of administrative responsibilities and reductions in the number of 

commercial, financial, and law enforcement database queries due to the automation of the 

commercial database and networking functions. 

Information Technology Funding Realignment -$3,449,000 / +0 FTE 

This program decrease realigns funding from the terminated BSA Direct Retrieval and 

Sharing project. 

Program Reinvestment ..................................................................+$2,897,000 / +0 FTE 

BSA Data Management and Analysis +$2,897,000 / +0 FTE 

BSA Data Management and Analysis encompasses the data management and quality 

activities of FinCEN, including the original objectives from the BSA Direct retrieval and 

sharing (R&S) program. Investments in information technology are at the core of 

FinCEN's national security mission to make BSA information available for hundreds of 

government agencies and international partners to fight terrorism and money laundering. 

With this reinvestment, FinCEN will focus resources to improve BSA data quality and 

integrity, resulting in expanded utilization of the BSA information. 

Program Increases .........................................................................+$2,261,000 / +7 FTE 

Improve BSA Effectiveness/Consistency +$1,139,000 / +5 FTE 

Effective administration of the Bank Secrecy Act (BSA) requires timely exchange of 

information, consistent BSA application, and tailored outreach to assist regulated 

industries to better target their limited resources. The initiative aims to realize 

efficiencies for all entities subject to the regulatory framework. Greater efficiency will 

reduce regulatory burden on the financial industry, while at the same time enhancing 

effectiveness in providing law enforcement and regulators with information needed to

combat the financing of terrorism and money laundering. Proposed funding will enable 

FinCEN to better align regulatory requirements with global risk management strategies 

developed by the largest global conglomerates, while also reducing risk-based obligations 

on some of the smallest institutions. A significant part of this effort will be to avoid 

potential anti-competitive effects through enhanced consistency of application across 

different sectors of the financial industry. Some sectors subject to the USA PATRIOT 

Act mandate, such as the insurance sector, have yet to be fully brought under the BSA 

administration and compliance framework. FinCEN must devote additional resources to 

clarifying regulatory requirements to financial industries and leveraging partner 

regulatory agencies, including the federal banking agencies, SEC, CFTC, IRS and 

various regulators in 50 states covering the banking, securities, insurance, money services 

business, and gaming industries. Requested funding will enable FinCEN to tailor present 

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and future requirements, expand outreach efforts, and execute information sharing 

agreements with and provide related support to additional state regulatory authorities. 

Overall, funding will enable FinCEN to increase coordination of regulatory agencies

from 40 to 62 percent of those with jurisdiction over industries covered under the BSA, 

while at the same time easing industry compliance obligations by reducing public 

reporting and recordkeeping obligation time. 

Strengthen Global Anti-Money Laundering Efforts +$865,000 / +2 FTE 

FinCEN works with FIUs around the world to intensify international anti-money 

laundering collaboration and combat terrorist financing. In recent years, FinCEN, 

together with other U.S. agencies, has invested significant resources in the FIUs to 

strengthen their investigative and analytical capacity to provide greater information on 

money laundering/terrorist financing activities. Additional resources are required to take 

further advantage of the FIUs newly expanded and strengthened capacities, including 

expanded information exchanges to benefit U.S. law enforcement. The Egmont Group 

has grown from 58 foreign FIU members in FY 2001 to an anticipated 106 members by 

FY 2008. As a result, the number of FIU case requests increased 23 percent from FY 

2005 to FY 2007, and continued growth is projected. This increased case load has 

resulted in a backlog that, without additional resources, will reach 666 by FY 2010, and 

has already lengthened the average completion time to 5.5 months, more than five times 

the Egmont Group best practices timeframe. Results from FinCEN's 2006 customer 

satisfaction survey indicated that almost one-third of FIU respondents were dissatisfied 

with the case response time and reflected a desire for FinCEN to conduct more in-depth 

research on case requests. FinCEN estimates that approximately 20 percent of FIU case 

requests can be improved by conducting more advanced analysis. Additional funding 

will allow FinCEN to reduce the FIU case request backlog from 128 in FY 2009 to 4 by 

FY 2011, reduce the average completion time to less than one month, and redirect a 

portion of resources to expand analytical efforts on applicable FIU cases, beginning with 

0 percent in FY 2009 and reaching 20 percent in FY 2011. 

Increase Physical Security +$257,000 / +0 FTE 

FinCEN will utilize FY 2009 funds to enhance its Physical Security Program to mitigate 

vulnerabilities. Currently, FinCEN leases over 240,000 square feet of office space for its 

Virginia headquarters location. Presently 440 federal employees and other personnel 

have access to this office space. A recent review of FinCEN's physical security 

environment by the Federal Protective Service identified security vulnerabilities. This 

funding will allow FinCEN to procure additional security equipment to enhance its 

Physical Security Program in order to mitigate some of those vulnerabilities. 

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 2.2 – Operating Levels Table 

Dollars in Thousands

Bureau: Salaries and Expenses

FY 2007 Enacted

FY 2008 

President's 

Budget

Cong. Action 

including 

Recission

FY 2008 Enacted 

Level

FY 2009 

Requested Level

FTE 326 352 334 343

Object Classification:

 11.1 - Full-time permanent 28,773 31,531 0 31,531 33,092

 11.3 - Other than full-time permanent 284 284 0 284 284

 11.5 - Other personnel compensation 526 526 0 526 526

 11.8 - Special personal services payments 0 0 0 0 0

 12 - Personnel benefits 7,414 8,433 0 8,433 9,030

 13 - Benefits for former personnel 0 0 0 0 0

 21 - Travel and transportation of persons 1,032 1,190 0 1,190 1,216

 22 - Transportation of things 0 0 0 0 0

 23.1 - Rental payments to GSA 4,800 5,117 0 5,117 5,343

 23.2 - Rental payments to others 43 1,328 0 1,328 70

 23.3 - Comm, utilities, and misc charges 996 0 0 0 1,364

 24 - Printing and reproduction 250 400 0 400 450

 25 - Other contractual Services 0 0 0 0 0

 25.1 - Advisory and assistance services 522 1,815 0 1,815 1,815

 25.2 - Other services 9,354 11,758 0 11,758 13,136

 25.3 - Other purchases of goods and services from Govt.

accounts 

9,454 12,706 0 12,706 14,198

 25.4 - Operation and maintenance of facilities 960 960 0 960 960

 25.5 - Research and development contracts 0 0 0 0 0

 25.6 - Medical care 120 145 0 145 153

 25.7 - Operation and maintenance of equip 4,908 4,815 0 4,815 5,003

 25.8 - Subsistence and support of persons 0 0 0 0 0

 26 - Supplies and materials 369 409 0 409 444

 31 - Equipment 3,411 4,427 0 4,427 4,251

 32 - Land and structures 0 0 0 0 0

 33 - Investments and loans 0 0 0 0 0

 41 - Grants, subsidies, and contributions 0 0 0 0 0

 42 - Insurance claims and indemnities 0 0 0 0 0

 43 - Interest and dividends 0 0 0 0 0

 44 - Refunds 0 0 0 0 0

Total Budget Authority $73,216 $85,844 $0 $85,844 $91,335

Budget Activities:

 BSA Administration and Analysis 64,780 76,889 0 76,889 82,157

 Regulatory Support Programs 8,436 8,955 0 8,955 9,178

Total Budget Authority $73,216 $85,844 $0 $85,844 $91,335

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2.3 – Appropriations Detail Table 

Dollars in Thousands

FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

New Appropriated Resources:

BSA Administration and Analysis 302 $61,386 326 $64,780 334 $76,889 343 $82,157 2.69% 6.85%

Regulatory Support Programs 7,924 8,436 8,955 9,178 2.49%

Subtotal New Appropriated Resources 302 $69,310 326 $73,216 334 $85,844 343 $91,335 2.69% 6.40%

Other Resources:

Offsetting Collections - Reimbursable 1,960 2,600 5,251 5,251 0.00%

Available multi-year/no-year funds 5,872 9,418 7,343 2,500 -65.95%

Transfers In/Out 225 225 225 225

Subtotal Other Resources 0 $8,057 0 $12,243 0 $12,819 0 $7,976 -37.78%

Total Resources Available for Obligation 302 $77,367 326 $85,459 334 $98,663 343 $99,311 2.69% 0.66%

FY 2008

Resources Available for Obligation

FY 2007 FY 2007 FY 2008 FY 2009

Obligations Enacted Enacted Request to FY 2009

% Change

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

representation expenses; and for assistance to Federal law 

enforcement agencies, with or without reimbursement, 

[$85,844,000] $91,335,000 of which not to exceed 

$16,340,000 shall remain available until September 30, 

[2010] 2011; and of which [$8,955,000] $9,178,000 shall 

remain available until September 30, [2009] 2010: 

Provided, that funds appropriated in this account may be 

used to procure personal services contracts. 

2C – Legislative Proposals 

FinCEN does not have any legislative proposals for FY 2009. 

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Section 3 – Budget and Performance Plan

This table lists all FY 2009 resources by strategic goal, objective and outcome outlined in 

the FY 2007-2012 Treasury Department Strategic Plan. The Treasury Strategic Plan is a 

corporate level plan for the Department that 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.treas.gov/offices/management/budget/strategic-plan/

3.1 – Budget by Strategic Outcome 

Dollars in Thousands

TREASURY Strategic Outcome FY 2008 FY 2009 Percent

Enacted Request Change

AMOUNT AMOUNT AMOUNT 

 U.S. & intl financial sys 91,095 96,586 6.0%

Total $91,095 $96,586 6.0%

3A – BSA Administration and Analysis ($82,157,000 from direct appropriations and 

$5,251,000 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 filed by the regulated 

industries, as well as analytic activities. Internationally, FinCEN promotes the 

development of anti-money laundering regimes through training and technical assistance. 

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

combating financial crime by facilitating the exchange of investigative information; 

identifying foreign and domestic 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 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 certain 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. 

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

educate other jurisdictions about the BSA regulatory regime; working to establish 

international anti-money laundering/counter-terrorist financing regulatory standards and 

norms; and improving the expertise and capabilities of personnel with anti-money 

laundering/counter-terrorist financing missions. 

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

investigating financial 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 transaction mechanisms. Additionally, FinCEN identifies 

individuals and networks involved in suspicious financial activity, referring that 

information to appropriate law enforcement agencies. 

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 direct access to BSA information to 

authorized law enforcement, regulatory, and intelligence agencies. FinCEN will continue 

to integrate and modernize the various components of the BSA data collection and 

sharing systems. These efforts include upgrading the BSA E-Filing system to provide a 

more robust collection function, improving the quality of BSA data by preventing the 

omission of critical information, validating the information collected, and upgrading the 

BSA analytical tools used by FinCEN analysts. 

Other Resources: Offsetting collections and reimbursements totaling $5,251,000 are 

collected to support joint activities with other agencies such as the Department of State 

for technical assistance provided to foreign countries and Treasury Forfeiture Fund for 

special projects to support law enforcement. 

3.2.1 – BSA Administration and Analysis Budget and Performance Plan 

BSA Administration and Analysis Budget 

Activity

FY 2005 FY 2006 FY 2007 FY 2008 FY 2009

Resource Level Obligated Obligated Obligated Enacted Request

 Appropriated Resources $71,922 $64,458 $64,780 $76,889 $82,157

 Reimbursable Resources $1,195 $4,473 $1,541 $5,251 $5,251

Total Resources $73,117 $68,931 $66,321 $82,140 $87,408

Budget Activity Total $73,117 $68,931 $66,321 $82,140 $87,408

FinCEN - 12 
BSA Administration and Analysis Budget 

Activity

 Measure FY 2005 FY 2006 FY 2007 FY 2008 FY 2009

Actual Actual Actual Target Target

Average time to process enforcement matters 

(in Years) (E) 

 1 1 1 1 1

Percentage of Regulatory Resource Center 

Customers rating the guidance received as 

understandable 

 % 94.00% 91.00% 90.00% 90.00%

Percentage of bank examinations conducted

by the Federal Banking Agencies indicating a 

systemic failure of the anti-money laundering

program rule.

 % % 5.20% 5.20% 5.20%

Percentage of customers finding FinCEN�s 

analytic reports highly valuable. 

 % % 82.00% 79.00% 80.00%

Percentage of customers satisfied with the 

BSA E-Filing (Oe) 

 % 92.00% 94.00% 90.00% 90.00%

Number of federal and state regulatory

agencies with which FinCEN has concluded 

memoranda of understanding/information

sharing agreements. 

 41 48 50 52 59

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

Description of Performance 

In the regulatory area, FinCEN achieved its FY 2007 targets related to increasing 

compliance oversight through establishment of information sharing MOUs with 

regulators and the Regulatory Resource Center customer satisfaction rating. FinCEN also 

established a baseline for a new performance measure relating to industry compliance for 

depository institutions.

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 with regulators. In FY 2007, FinCEN executed two 

additional such agreements and has met its FY 2007 target of 50. With the resources 

requested in FY 2009, FinCEN can increase the number of compliance MOUs to 59, with 

an ultimate goal of 73 by 2011. These information exchanges help ensure effective 

application of the BSA regulations across all regulated financial service industries by 

providing vital compliance data across all industries subject to BSA regulations. 

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

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

through imposition of civil money penalties in appropriate matters. Timely enforcement 

action communicates urgency to financial institutions, and is paramount to deterring noncompliance. In FY 2007, FinCEN experienced a slight increase in the average processing 

time, exceeding the 1.0 year average by 21 days, resulting in an average of 1.1 years. 

This was the result of two enforcement cases that closed in the fourth quarter of FY 2007 

after abnormally long periods of time. Each of those enforcement actions was taken on a 

joint/concurrent basis with both the Department of Justice and the respective financial 

supervisor(s), which also had to complete their respective investigations. Moreover, the 

process of coordination with other interested government authorities, which itself is a 

Departmental priority, will often require longer time periods than unilateral actions. As 

such, the time periods of these two cases were outliers, and FinCEN will reconsider in the 

future whether the processing time target is appropriate for joint enforcement actions. 

FinCEN - 13 
FinCEN established an FY 2006 baseline of 94 percent of Regulatory Resource Center 

customers rating regulatory guidance received as understandable, and a target of 

maintaining at least a 90 percent level in FY 2009. In FY 2007, FinCEN met its target 

with 91 percent rating the guidance received as understandable. Providing

understandable guidance to financial institutions is critical to their establishing antimoney laundering programs that comply appropriately with the BSA. 

FinCEN established a baseline for the new performance measure “percentage of bank

examinations conducted by federal banking agencies indicating a systemic anti-money 

laundering program failure” in FY 2007. This measure provides an indicator to FinCEN

of trends in regulatory compliance and examination efforts. FinCEN will continue to

work toward developing additional improved outcome measures to address the impact of

program activities on preventing the misuse of the financial system by those engaged in 

illicit activities. 

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, as well as progress toward 

achieving the bureau’s long term goal of increasing the percentage of advanced analytical 

products produced by FinCEN analysts. 

In FY 2006, FinCEN revised its value of analytical products measure to more accurately 

target its disparate audiences as well as its different products. The reformulated measure 

more closely ties to how BSA information is used by law enforcement, regulators and 

international partners to identify, investigate, and prevent abuse of the financial system. 

In FY 2007, FinCEN surpassed its target of 78 percent with 82 percent of its customers 

finding the analytic products highly valuable. 

FinCEN has also reevaluated its long term goals for increasing the percentage of 

advanced analytical products and revised the methodology based on the increased support 

provided to foreign FIU counterparts. FinCEN found that continuing to measure the 

percentage of complex analytic products in the manner originally developed will result in 

an apparent decrease in complexity beginning in FY 2007. The reason for this is the 

significant projected increases of FIU cases. Since FIUs are prohibited from receiving 

direct access to BSA information, FinCEN performs the required research and analysis 

on these cases. The significant projected increase in the number of FIU cases, which are 

non-discretionary and non-complex, skews the complexity measure. FinCEN originally 

projected a target of 50 percent in FY 2007 and a sustained rate of 75 percent complexity 

by FY 2008. The goal for FY 2009, with the additional resources requested, is to achieve 

50 percent, with an ultimate long-term goal of 70 percent by 2011. 

In the management, use, and security of BSA information, FinCEN conducted a baseline 

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 2007 target was to maintain at 

least a 90 percent satisfaction level. In FY 2007, FinCEN exceeded its target with 94 

percent of respondents being satisfied with the BSA E-Filing system. This measure ties 

FinCEN - 14 
to the FinCEN goal of enhanced management, use, and security of BSA information. 

The information and the technology used to facilitate analysis are at the core of FinCEN’s 

mission to deter and detect criminal activity, and safeguard financial systems from abuse 

by promoting transparency in the U.S. and international financial systems. FinCEN will 

continue to satisfy E-filing customer expected service levels with at least a 90 percent 

satisfaction level in FY 2009. FinCEN developed a survey to further assess customer 

satisfaction by authorized law enforcement, regulatory, and intelligence agencies that 

directly access BSA information. The 2007 survey result of 74 percent establishes the 

baseline for this measure. 

3B – Regulatory Support Programs ($9,178,000 from direct appropriations): This 

activity supports implementation, strengthening and clarification of the programmatic 

(anti-money laundering, Customer Identification Program, and suspicious activity 

reporting), recordkeeping, and reporting requirements of the BSA for financial 

institutions subject to those requirements. FinCEN will continue efforts with the IRS, 

especially related to the money services business (MSB) industry to ensure compliance, 

respond to public inquiries, distribute forms and publications, and support collection and 

maintenance of BSA information. This may include enhancing the capability to correct 

identified data quality issues, enhance electronic filing, potentially explore overall forms 

design, and other related enhancements to the BSA collection and dissemination systems. 

These resources also fund IRS BSA compliance activities for non-bank financial 

institutions, especially related to the money services business industry. 

3.2.2 – Regulatory Support Programs Budget and Performance Plan

Regulatory Support Programs Budget 

Activity

FY 2005 FY 2006 FY 2007 FY 2008 FY 2009

Resource Level Obligated Obligated Obligated Enacted Request

 Appropriated Resources $0 $8,436 $8,436 $8,955 $9,178

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

Total Resources $0 $8,436 $8,436 $8,955 $9,178

Budget Activity Total $0 $8,436 $8,436 $8,955 $9,178

Regulatory Support Programs Budget 

Activity

 Measure FY 2005 FY 2006 FY 2007 FY 2008 FY 2009

Actual Actual Actual Target Target

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

Description of Performance. 

FinCEN achieved the following quantifiable results in FY 2007 and plans to enhance 

these results with the FY 2009 funding requested above: 

• Increased the number of registered MSBs to 38,379 as of December 19, 2007. 

FinCEN plans to maintain or exceed this level by FY 2009; 

• Continue to analyze SARs on a monthly basis for indications of possible unregistered 

MSBs, coordinating with law enforcement and state regulatory agencies on 

FinCEN - 15 
appropriate outreach, and continue efforts to educate MSBs regarding requirements for 

registration by publishing guidance and participating in industry outreach events. 

From September 2002 through August 2007, 4,770 individuals/entities suspected of 

being engaged in unregistered MSB activity have been identified through a review of 

SARs filed by depository institutions; and 

• Continue to investigate methods for measuring the extent of BSA compliance among 

MSBs. 

For detailed information about each performance measure, including definition, 

verification and validation, please go to: 

http://www.treasury.gov/offices/management/dcfo/accountability-reports/2007-par.shtml

FinCEN - 16 
Section 4 – Supporting Materials 

4A – Human Capital Strategy Description 

FinCEN’s strategic human capital objective to attract, develop and retain a highperforming diverse workforce includes efforts to improve workforce planning and 

deployment, leadership and knowledge management, establish a results-oriented 

performance culture, promote diversity, recruit and retain a talented workforce, and 

improve accountability. 

The FinCEN FY 2008-2012 Strategic Plan includes areas that require employees with 

enhanced skills. Additionally, the Strategic Plan has a management goal of a properly 

staffed and fully developed organization capable of providing the highest quality public 

service. 

In terms of competitive sourcing, FinCEN submitted its FY 2007 FAIR Act Inventory to 

the Department in April 2007, and continues to rely upon the private sector to perform 

commercial activities, especially in the information technology environment. 

FinCEN recently completed several organizational realignments throughout the bureau to 

more closely align functions and support the mission of the organization. For example, 

FinCEN’s regulatory division has established an office to provide outreach to institutions 

that are subject to the BSA programmatic, recordkeeping, and reporting requirements. 

Additionally, the information technology division is establishing a customer service 

center that provides FinCEN employees with the support to better serve external 

customers. 

FinCEN leaders and managers effectively manage people and sustain a learning 

environment that drives continuous improvement in performance. In FY 2007, FinCEN 

continued its aggressive training strategy for managers and trained the majority of 

managers in executive leadership competencies. In addition, seven employees 

participated in government-sponsored leadership development programs. 

FinCEN estimates that 25 percent of the current workforce will be eligible for retirement 

between now and FY 2011. To confront this management challenge, the bureau is 

emphasizing leadership development activities at all levels. In FY 2007, FinCEN leaders 

participated in a competency assessment that resulted in the development of a bureau 

leadership competency model. That model defines what FinCEN values in its leaders and 

identified the critical competencies required to be successful, and formed the basis for 

FinCEN’s Leadership Development Program. FinCEN will focus initial development 

efforts on three of the eight competencies included in the Leadership Competency Model: 

Managing Change, Communicating Effectively, and Developing Others. Components of 

the Leadership Effectiveness through Active Development (LEAD) program will include 

an annual skills assessment, a minimum of 24 hours of leadership/management training

each year, books and journal articles, and a curriculum for high potentials. In March 

2007, FinCEN initiated a monthly newsletter entitled “SMART” (Stimulate Managers’ 

FinCEN - 17 
Reflective Thinking); this newsletter highlights articles that discuss the latest, most 

innovative thinking on leadership and leadership development. As part of leadership 

development, FinCEN offered “Leadership Skills for Non-Supervisors” training to 40 

employees. 

In order to create a results-oriented, high performing workforce, FinCEN abolished the 

pass/fail performance system in FY 2005 and established a new five-tier performance 

management system. The new performance system requires that each employee be 

placed on performance standards that include three individual commitments linked 

directly to the strategic plan. The new performance system allows managers to 

differentiate performance levels among employees and hold employees accountable for 

meeting specified performance goals and targets. In addition, each employee is also 

placed on an annual Individual Development Plan to identify areas for further growth and 

development. 

Subsequently, FinCEN implemented the Awards and Recognition Program, including the 

Director’s Awards and Recognition Program. In FY 2006, 67.5 percent of the workforce 

was rated above the fully successful level and were appropriately recognized, while 1.3 

percent was rated below fully successful and appropriate remedial actions were taken.

FinCEN completed several efforts to ensure a diverse workforce is maintained. Major 

efforts are listed below: 

• Continued participation in the Treasury Diversity Council and its support group; 

• Maintained a Diversity Advisory Committee; and 

• Continued a mandatory Equal Employment Opportunity (EEO)/Diversity element 

in all supervisory performance plans to address EEO principles, workplace 

conflict, supporting EEO plans and diversity hiring requirements. 

FinCEN is committed to developing defined paths for career progression, mentoring and 

coaching programs to identify and grow talent, and enhancing the skills of existing 

employees. In FY 2007, FinCEN’s Information Technology (IT) Specialists participated 

in the IT Workforce Capability Assessment. Results of that assessment determined the 

specialized skills training for FinCEN’s IT Specialists. FinCEN conducted a skills gap 

assessment for its mission critical Intelligence Research Specialists. Results of that 

assessment will target training needs for the remainder of the fiscal year. FinCEN will 

also complete similar skills gap assessments for its mission critical Regulatory Specialists 

and Law Enforcement Liaison Specialists in FY 2008. In FY 2007, specialized training 

was provided on improving job performance in these occupations. FinCEN’s leadership 

actively encourages employees to take advantage of available training opportunities. 

Additionally, FinCEN took advantage of various hiring authorities and flexibilities within 

the last year. For example, in FY 2007, four students were hired under the Student 

Temporary Employment Program (STEP); 16 in FY 2006, and 10 in FY 2005. In FY 

2007, two students were hired under the Student Career Employment Program (SCEP). 

FinCEN utilized both the Veterans Employment Opportunity Act (VEOA) and the 

Veteran Rehabilitation Act (VRA) by making two appointments over the past two years. 

FinCEN - 18 
FinCEN - 19 

As reported in the Quarterly Hiring Timeline Report over the last four quarters, FinCEN 

averaged 40.25 days, which is under the 45 day hiring timeframe. 

Results from the 2006 Federal Human Capital Survey indicated that 80 percent of 

FinCEN employees know how their work relates to the agency’s goals and priorities and 

76 percent feel that they are held accountable for achieving results. FinCEN continues to 

clearly show distinctions of and consequences in levels of performance. FinCEN is 

following up on some issues from the latest Federal Human Capital Survey to identify 

ways to increase scores by improving employee satisfaction. FinCEN continues to 

review the performance management system to identify areas for improvement. 
FinCEN - 20 

4.1 – Summary of IT Resources Table 

Dollars in Thousands

Information Technology Investments

Budget Activity

FY 2006 

Enacted

FY 2007 

Enacted

FY 2008

Enacted

FY 2009 

Request

Non-Major IT Investments

BSA Administration and Analysis 10,378 11,424 10.1% 17,273 51.2% 18,108 4.8%

Infrastructure Investments 

BSA Administration and Analysis 8,295 8,474 2.2% 9,711 14.6% 9,800 0.9%

FinCEN EA Investment

BSA Administration and Analysis 100 203 103.0% 237 16.7% 385 62.4%

Total IT Investments

BSA Administration and Analysis 18,773 20,101 7.1% 27,221 35.4% 28,293 3.9%

% Change

from FY06 to 

FY07

% Change 

from FY07 to 

FY08

% Change 

from FY08 to

FY09
4B – Information Technology Strategy 

Information and the technology used to facilitate its analysis are at the core of FinCEN’s 

mission to deter and detect criminal activity, and safeguard financial systems from abuse 

by promoting transparency in the U.S. and international financial systems. However, 

FinCEN is currently facing a critical need to improve the quality and accessibility of its 

data and increase responsiveness to stakeholders by introducing flexible and innovative 

technical solutions. 

In 2006, the number of BSA reports filed rose by 12 percent to approximately 17.6 

million, with more than one million SARs for all covered industries. FinCEN recognizes 

the enormous obligation on one of its critical stakeholders—regulated financial 

institutions. Feedback from financial institutions, obtained through a recent survey on efiling, indicated that FinCEN needs to streamline how it captures information through the 

various forms and simplify means to submit information. 

Based on the growing need to reduce the obligation on the financial institutions while 

increasing the quality and timeliness of the information provided to the bureau’s 

stakeholders, FinCEN has launched an information technology modernization vision and 

transition strategy (IT Modernization V&S). This strategy spans all of the bureau’s lines 

of business and will serve as the organization’s roadmap for aligning its IT portfolio with 

its business objectives and processes. 

Over the last several months, the integrated team dedicated to this initiative has 

documented the current business operating model and future business transformation 

goals and objectives, identified capability gaps, and created an actionable, five-year 

enterprise transition strategy with near-term (0-2 years) and long-term (3-5 years) 

business process reengineering and IT initiatives. 

As a result of the IT Modernization V&S effort, FinCEN has developed its five-year 

strategic vision, which focuses on two keys aspects—information management and 

analysis, and stakeholder relations and collaboration. By establishing an enterprise-wide 

information management and analysis framework, FinCEN will be equipped with better 

decision-making ability and control of BSA data collection and processing, as well as 

improved data quality and integrity. FinCEN also envisions implementing emerging 

technology that provides the capability to securely manage stakeholder contact 

information and provide a proactive mechanism to identify stakeholder needs and 

continuously improve customer service. 

As next steps, FinCEN will use the results of the IT Modernization V&S effort to develop 

a new IT Strategic Plan (to be released in FY 2008) and realign its IT initiative portfolio 

by enhancing existing systems and introducing proven shared services and infrastructure. 

In addition, as FinCEN moves forward, it will continue to collaborate with the IRS on 

how best to partner on new technologies and explore opportunities that reduce the overall 

cost to the Department, while still meeting the needs of its various stakeholders. 
This five-year IT Modernization V&S supports FinCEN’s goal to enhance the 

management, use and accessibility of BSA information and the Department’s goal to 

prevent terrorism and promote the nation’s security through strengthened international 

financial systems. Specifically, by increasing the timeliness and quality of the BSA 

information, FinCEN will enable stakeholders to more quickly identify terrorist and 

criminal threats. 

FinCEN - 22 
4.2 – PART Evaluation Table 

PART Name: Bank Secrecy Act Data Collection, Retrieval and Sharing 

Year PARTed: 2005 

Rating: Moderately Effective 

OMB Major Findings/Recommendations 

• The program has long-term performance measures that focus on the program’s 

purpose and strategic goals, but more work is needed to measure data quality. 

• Federal Managers are held accountable for cost, schedule and performance 

results. However, some activities are managed by another entity and are outside 

the scope of the performance measures. 

• The program can show improved efficiencies and cost effectiveness for collecting 

and sharing data. The program has been able to show substantial increases in the 

number of users directly accessing data, and the share of filings submitted 

electronically. 

Bureau Actions Planned or Underway 

• FinCEN created a measure and targets to track the number of top 650 filers who 

file reports electronically. FinCEN will continue to monitor the progress and 

tracking of this measure and identify where improvements can be made. This will 

be a critical project as this measure is linked to the long-term E-Filing goals. 

• FinCEN will survey BSA users to systematically find out if users are receiving 

the information they need in a timely manner, if the information they are 

receiving is helpful, and if there are any problems with the information, format, 

etc. A survey of BSA E-Filers was completed, and FinCEN began surveying the 

Secure Outreach and WebCBRS users. FinCEN plans to examine both surveys 

and determine appropriate improvements. 

• FinCEN has taken steps to create a performance measure to measure the quality 

of information provided on Suspicious Activity Reports. In FY 2006, FinCEN 

established a measure, including a target rate, that tracks the critical field 

omission rate of E-Filed SARs to measure the quality of information provided on 

SARs. FinCEN will continue to monitor duplicate SAR data for filers with 

systemic duplicate filings, implement established referral procedures on all filers 

with systemic omission rate problems, and monitor future duplicate SAR data to 

verify referred institutions have corrected their systemic problems. 

• Increase the quality of BSA data by correcting data quality issues. In FY 2007, 

FinCEN, in collaboration with IRS, initiated a BSA Data Management framework 

process to increase the quality of BSA data. This initiative identified issues that

FinCEN - 23 
affect the quality of BSA data, which were prioritized. FinCEN and IRS have 

established a process for updating and tracking these issues. In FY 2008, FinCEN 

and IRS plan to implement a minimum of two releases of system changes to 

address between 20 percent – 25 percent of the issues prioritized as of July 2007. 

FinCEN and IRS will meet quarterly to review their progress toward improving 

BSA data quality. FinCEN will also evaluate the BSA Information framework 

process established to measure the overall progress and identify ways to simplify 

or improve the process. 

• FinCEN will look at ways to reduce filing burden on the financial community, 

including streamlining reporting obligations and increasing feedback and notices 

to filers. Progress will be tracked and reported to stakeholders/published by 

FinCEN. 

• FinCEN will work with stakeholders, through a formal partnership established in 

2007, to identify additional steps on how to increase efficiency in completing and 

filing required reports. In order to highlight and track progress, FinCEN will 

quantify and publish the reduction in filing burden. 

FinCEN - 24 
PART Name: Bank Secrecy Act (BSA) Analysis 

Year PARTed: FY 2006 

Rating: Adequate 

OMB Major Findings/Recommendations 

• FinCEN currently administers a survey to its customers to evaluate the impact and 

usefulness of its analytic products. The response rate for 2006 was significantly 

increased for financial institutions and foreign intelligence units (FIUs), but more 

work is needed to increase the response rate for domestic law enforcement 

customers. 

• FinCEN currently administers a survey to its customers to evaluate the impact and 

usefulness of its analytic reports, but more work is needed to develop a method 

for better assessing the law enforcement impact of FinCEN’s analytic products. 

• FinCEN has developed plans to expand the percentage of advanced analytic 

products that it produces, but significant effort will be required to achieve its 

long-term target of 75 percent in FY 2008. FinCEN has increased the percentage 

of advanced analytic products from 1.6 percent in FY 2004 to 39 percent in FY 

2006. 

Bureau Actions Planned or Underway 

• Developing a plan to improve the survey response rate from domestic law 

enforcement. FinCEN has devised a plan to improve its survey response rate and 

will continue to monitor the response rates and make adjustments as necessary. 

• Evaluating the feasibility of better assessing law enforcement impact of FinCEN's

products. During FY 2007, FinCEN took numerous steps, including meeting with 

internal and external stakeholders, to evaluate the options for better assessing the 

law enforcement impact related to the utility of BSA data. In FY 2008, based on 

the information collected, FinCEN will draft a recommendation on the next steps 

to implement a process to collect information that would quantify the impact of 

utilization of BSA data to law enforcement. 

• Developing measures of the impact of FinCEN's efforts to strengthen anti-terrorist 

financing and anti-money laundering programs worldwide. In FY 2007, FinCEN 

determined that an annual customer survey would be the most appropriate 

mechanism for measuring the impact of FinCEN's efforts to strengthen antiterrorist financing and anti-money laundering programs worldwide. In the 

remainder of FY 2007, FinCEN: identified international liaison activities that 

could be utilized to measure impact, drafted a survey to solicit customer input, 

and created a database to capture requisite contact information for potential 

respondents. In FY 2008, FinCEN will administer the survey and review and 

analyze the response rate. 

FinCEN - 25 
PART Name: Bank Secrecy Act (BSA) Administration 

Year PARTed: 2006 

Rating: Results Not Demonstrated 

OMB Major Findings/Recommendations 

• Questions have been raised concerning compliance and burden issues relating to 

the regulations FinCEN issues, and more time is needed to examine the costs and 

benefits of the reporting requirements. 

• Although FinCEN has made progress in executing memoranda of understanding 

(MOUs) governing the exchange of information with federal and state regulatory 

agencies, additional time is needed to ensure BSA compliance in more vulnerable 

industries, particularly the money services business industry. 

• The program has annual performance measures that focus on the implementation 

of the BSA, such as the number of MOUs that have been entered into, but more 

work is needed to measure the impact of program activities on preventing the 

misuse of the financial system by those engaged in illicit activities. 

Bureau Actions Planned or Underway 

• Expanding outreach efforts to certain targeted industries to augment their 

understanding of the value of BSA data. FinCEN has developed a BSA value 

presentation for standard outreach presentations and training sessions targeted 

toward depository institutions presented by FinCEN. In FY 2008, FinCEN will 

continue including the BSA value presentation in standard outreach presentations, 

with a focus on expanding use of presentations to involve other covered 

industries. 

• Developing a long-range plan to expand compliance oversight and reporting by 

state regulators for newly covered industries. FinCEN is currently in discussions 

with the IRS, the federal banking agencies, and state regulatory agencies and their 

associations to develop a long-range plan for compliance oversight over the 

money services business industry. 

• Developing measures of the impact of program activities on preventing the 

misuse of the financial system by those engaged in illicit activities. In FY 2007, 

FinCEN developed a working group to examine options and data available to 

create a meaningful performance measure to assess the impact of project activities 

on preventing the misuse of the financial system by those engaged in illicit 

activities and determined a survey of its regulatory partners will best capture the 

performance. In FY 2008, FinCEN will develop and conduct the survey and 

establish a baseline and future targets.

FinCEN - 26 
• FinCEN will meet with staff from the Office of Information and Regulatory 

Policy (OIRA) to discuss the tools and methods they employ when making 

cost/benefit decisions related to regulations. 

For a complete list of PART results visit the following website: 

http://www.whitehouse.gov/omb/expectmore/all.html

FinCEN - 27