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 2009 FY 2010 FY 2011

Enacted Enacted Request $ Change % Change

 BSA Administration and Analysis $82,287 $101,694 $91,151 ($10,543) (10.4%)

 Regulatory Support Programs $9,178 $9,316 $9,268 ($48) (0.5%)

Total Appropriated Resources $91,465 $111,010 $100,419 ($10,591) (9.5%)

Total FTE 330 331 327 (4) (1.2%)

FY 2011 Priorities 

FinCEN’s efforts clearly support the Treasury Secretary’s priority to restore confidence 

in the financial system by harnessing all of its authorities to support domestic and global 

efforts in the fight against financial fraud. Specifically, FinCEN’s activities to safeguard 

the financial system result in improved market integrity and heightened confidence in the 

financial system. FinCEN’s mission components continually enhance the Secretary’s 

priority in unique and complimentary ways. The regulatory component identifies 

financial industries and new payment methods vulnerable to money laundering, and 

develops corresponding policy and guidance to strengthen financial stability. The 

analytic component examines the Bank Secrecy Act (BSA) data filed by financial 

industries to identify vulnerabilities and financial fraud that undermine economic growth 

if left undetected. FinCEN has begun modernization of its BSA information technology 

system to ensure the effective management, accessibility, dissemination, and use of the 

highly sensitive confidential information collected under the BSA. This modernization 

will provide law enforcement and financial industry regulators better decision-making 

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

and analytical tools. This effort will improve government-wide efforts to detect criminal 

activity, including tax and financial fraud. 

FinCEN ‐ 1
Table of Contents 

Financial Crimes Enforcement Network ........................................................................ 1

Section 1 – Purpose ........................................................................................................... 3

1A – Description of Bureau Vision and Priorities .......................................................... 3 

1B – Program History and Future Outlook ..................................................................... 4 

Section 2 – Budget Adjustments and Appropriation Language ................................... 9

2.1 – Budget Adjustments Table .................................................................................... 9 

2A – Budget Increases and Decreases Description ........................................................ 9 

2.2 – Operating Levels Table ........................................................................................ 11 

2.3 – Appropriations Detail Table ................................................................................ 12 

2B – Appropriations Language and Explanation of Changes....................................... 12 

2C – Legislative Proposals ........................................................................................... 13 

Section 3 – Budget and Performance Plan ................................................................... 14

3.1 – Budget by Strategic Outcome .............................................................................. 14 

3.2.1 – BSA Administration and Analysis Budget and Performance Plan ................... 16 

3.2.2 – Regulatory Support Programs Budget and Performance Plan .......................... 17 

Section 4 – Supporting Materials .................................................................................. 19

4A – Human Capital Strategy Description ................................................................... 19 

4.1 – Summary of IT Resources Table ......................................................................... 22 

4B – Information Technology Strategy ........................................................................ 23 

4.2 – Program Evaluation ............................................................................................. 24 

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Section 1 – Purpose

1A – Description of Bureau Vision and Priorities 

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

within the Office of Terrorism and Financial Intelligence, plays a key role in supporting 

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

through strengthened international financial systems. FinCEN supports Treasury’s 

national security goal by identifying attempts to utilize the financial system for illicit 

dealings and by ensuring safer and more transparent U.S. and international financial 

systems through the administration of the Bank Secrecy Act (BSA). The bureau also 

supports Treasury’s other strategic goals by deterring noncompliance with tax laws 

promoting investigation of fraud and abuse/asset recovery, strengthening financial 

institutions and markets, and promoting compliance with laws and regulations. 

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

types of financial activity and to establish appropriate internal controls to guard against 

financial fraud, money laundering, terrorist financing, and other types of illicit finance. 

These reports and records have a high degree of usefulness in criminal, tax, and 

regulatory matters. Law enforcement agencies use BSA information, domestically and 

through exchanges with international counterparts, to identify, detect and deter financial 

fraud and money laundering. Acts of fraud and money-laundering are interconnected as 

the proceeds of these fraudulent activities are ultimately integrated into the financial 

system. Regulatory authorities use BSA information in promoting safety and soundness 

of financial institutions and markets in carrying out prudential supervision, including to 

ensure compliance with BSA requirements. 

FinCEN also serves as the nation’s Financial Intelligence Unit (FIU). An FIU serves as a 

national center to collect, analyze, disseminate, and exchange information pursuant to a 

country’s anti-money laundering/counter-terrorist financing (AML/CFT) legislation and 

regulations. This includes information about suspicious or unusual financial activity 

reported by the financial sector. FinCEN has a unique authority to facilitate law 

enforcement investigations involving transnational criminal activity and financial flows, 

by exchanging lead information with FIU counterparts in over 100 countries around the 

world. 

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

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

• 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, terrorism financing, and other 

illicit activity; and 

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

The total resources required to support FinCEN for FY 2011 are $120,419,000 including 

$100,419,000 for direct appropriation and $20,000,000 from offsetting collections. 

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1B – Program History and Future Outlook 

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

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

financial intelligence; enhancing financial anti-fraud efforts; enhancing international antimoney laundering and counter terrorist financing efforts and cooperation; and networking 

people, entities, ideas, and information. These activities to safeguard the financial system 

support the Secretary’s priorities to restore confidence in the financial system by 

improving market integrity and promoting confidence in the financial system. 

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

administration. This includes improving the consistency in the application of BSA 

regulations to regulated financial institutions, providing guidance regarding regulatory 

expectations, conducting studies to provide feedback to stakeholders, and initiating 

enforcement actions when appropriate. 

In FY 2009, FinCEN: 

• Issued an advisory to assist financial institutions in identifying questionable loan 

modification schemes and reporting that information to law enforcement, in support 

of a major Administration effort to combat foreclosure rescue scams. The advisory 

provided “red flags” for financial institutions that may indicate a loan modification 

or foreclosure rescue scam; 

• Released updated mortgage fraud analysis that demonstrates Suspicious Activity 

Reports (SARs) filed on suspected mortgage fraud increased 44 percent in the 12 

months ending in June 2008 compared with the prior year. The continued rate of 

growth in mortgage fraud SAR filings underscores the increased vigilance and 

awareness of financial institutions; 

• Issued a Notice of Proposed Rulemaking (NPRM) to re-designate and reorganize 

the BSA regulations in a new chapter within the Code of Federal Regulations. The 

re-designation and reorganization of the regulations in a new chapter is not 

intended to alter regulatory requirements. The regulations will be organized in a 

more consistent and intuitive structure that more easily allows financial institutions 

to identify their specific regulatory requirements under the BSA. The new chapter 

will replace 31 CFR Part 103; 

• Published a final rule that simplifies the current requirements for depository 

institutions to exempt their eligible customers from currency transaction reporting. 

The final rule was developed in accordance with the Government Accountability 

Office's recommendations, FinCEN's independent research, and with consideration 

of valuable industry feedback received during the public comment process; 

• Issued a BSA examination manual for money services businesses (MSBs), in 

collaboration with the Internal Revenue Service (IRS), state agencies responsible 

for MSB regulation, the Money Transmitter Regulators Association (MTRA), and 

the Conference of State Bank Supervisors (CSBS). The manual's risk-based 

approach empowers the examiner to decide what examination procedures are 

necessary to evaluate the MSB's AML program; and 

• Proposed revised rules and guidance that would permit certain affiliates of 

depository institutions as well as broker-dealers in securities, mutual funds, futures 

FinCEN ‐ 4
commission merchants, and introducing brokers in commodities, to share SARs 

within a corporate organizational structure for purposes consistent with Title II of 

the BSA. The revised rules will help financial institutions better facilitate 

compliance with the applicable BSA requirements and more effectively implement 

enterprise-wide risk management. 

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

financial system security and enhance U.S. national security. To ensure financial systems 

are resistant to abuse by money launderers, terrorists and other perpetrators of financial 

fraud and crimes, FinCEN will: 

• Clarify the scope of the MSB definitions to the extent consistent with 

appropriately managing money laundering risks in this industry, and continue to 

review the appropriate regulatory treatment of stored value providers within the 

MSB framework, consistent with the requirements of the Credit Card 

Accountability, Responsibility, and Disclosure Act; 

• Continue the outreach initiative to the financial services industry, which expanded 

from visits to the largest fifteen depository institutions in the U.S. to large MSBs, 

and will continue to expand to additional financial service industries; 

• Implement a simplified, revised regulatory structure, proposed in FY 2009, to 

reorganize BSA regulations under Chapter 10 of the Code of Federal Regulations; 

• Conduct analysis in support of efforts to combat mortgage loan fraud, building off 

prior analysis efforts to identify emerging trends, and continue to consider 

appropriate regulatory options; and 

• Strengthen oversight of recently-covered industries under the BSA, by beginning 

to sign information sharing agreements with state insurance regulators and 

working cooperatively with the IRS and state regulators on consistent, risk-based 

examination procedures. 

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

enhance law enforcement’s detection and deterrence of domestic and international 

financial fraud, money laundering, terrorism financing, and other illicit activity. FinCEN 

intends to improve its expert analysis of BSA data to provide early warning of emerging 

trends of fraud and other criminal abuse. This includes information exchange with 

counterpart FIUs in 116 countries that are members of the Egmont Group. 

 

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In FY 2009, FinCEN: 

• Continued to support efforts to combat mortgage fraud by publishing a report 

entitled Mortgage Loan Fraud Connections with other Financial Crime that 

examined a range of BSA reports to identify, evaluate and document 

interconnections between individuals involved in mortgage loan fraud and other 

financial crimes; 

• As part of the larger U.S. Government efforts to bring relief to America’s housing 

market and homeowners, FinCEN initiated an advanced targeting process to 

identify potential loan modification fraud perpetrators and to provide analytical 

support to investigations and prosecutions. FinCEN issued an advisory to 

financial institutions to help them identify and report questionable foreclosure 

rescue and mortgage modification schemes. Finally, FinCEN worked with 

Federal, state, and local agencies to combat the increase in mortgage foreclosure 

scams by networking agencies with common subjects to avoid overlapping 

investigations; 

• Participated in a multi-agency task force headed by the Special Inspector General 

for the Troubled Asset Relief Program (SIGTARP) to deter, detect, and 

investigate instances of fraud in the Term Asset-Backed Securities Loan Facility 

(TALF); 

• Held several inter-agency information sharing events to discuss sensitive data 

with the private sector. These events combined analytical findings and related 

law enforcement presentations for financial industry personnel, and provided an 

opportunity for industry personnel to share information on vulnerabilities and 

suspicious activities identified through their operations. A recent event included 

information sharing on money laundering and other financial crimes in Mexico 

and on the Southwest Border with representatives from banks that provide 

financial services to Mexico and the Southwest border region; 

• Produced a series of strategic international studies addressing complex money 

laundering schemes and examining money flows related to illicit activities; 

• Composed and disseminated 1,027 tactical reports to the other Egmont FIUs. 

These intelligence products are integral to investigations of money laundering and 

terrorist financing around the world; and 

• Continued outreach and liaison activities that enhance the quality and quantity of 

financial intelligence exchanged between FinCEN and foreign FIUs. These 

efforts included training and technical assistance programs that strengthen the 

global network of FIUs. 

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

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

financial fraud, money laundering, terrorism financing, and other illicit activity, FinCEN 

will: 

• Implement a process to capture and gauge analytic product relevance to support 

law enforcement; 

• Advance collaborative relationships with investigative and intelligence agencies 

to exploit SARs for proactive evaluation;

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• Expand working agreements with the government agency customer community 

within the provisions of 31 USC 5311 and financial institution AML compliance 

personnel on issues of strategic importance to FinCEN’s analytical objectives; 

• Improve analytical products and responsiveness to foreign government 

counterparts to strengthen the effectiveness of international AML/CFT efforts; 

and

• Increase joint analytical projects with foreign FIU counterparts through 

intensified operational engagements with key strategic partner FIUs.

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

information focus on maximizing utilization by improving the overall information 

infrastructure and enhancing information technology management capabilities. 

Improving data quality and access remains a priority for FinCEN. 

In FY 2009, FinCEN: 

• Retired magnetic media filing as a means to provide BSA information, enabling 

FinCEN to continue increasing the number of electronic filers. By the fourth 

quarter of FY 2009, 82 percent of all customers used E-Filing; 

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

submission to improve data quality and provide faster error notification. This 

validation process currently applies to Currency Transaction Report (CTR) forms 

and the Designation of Exempt Person form. Filers receive e-mail that their 

submitted file has errors and may access a designated error page to view batch 

validation error details; 

• Transitioned to Adobe LiveCycle from IBM WorkPlace forms during the third 

quarter of FY 2009. Moving to a widely used industry standard, Adobe LiveCycle 

brings E-filing in line with industry standards and offers improved forms usability 

for financial institutions; 

• Implemented functionality to provide the BSA E-filing community with SAR 

acknowledgement files that contains the unique identifier for each submitted form 

or batch of forms. This feedback will alert filers about errors contained in filings 

with the goal of increasing BSA data quality; ; 

• Implemented a collaboration and communities portal under the auspices of the 

Egmont Secure Web. This initiative leverages Web 2.0 Technologies and 

enables Egmont members to use secure communities for collaboration on sensitive 

special projects, as well as improve how each working group manages and shares 

documents and their contents; and 

• Completed all of the program/enterprise-level documentation defined in FinCEN’s 

System Development Life Cycle for the BSA Information Technology (IT) 

Modernization initiative. This documentation sets the foundation for the rest of 

the program and includes program management, business, and IT solution 

development documents, such as the Business System Requirements Report, the 

System Validation and Verification Plan, and the Transition Management Plan. 

 

FinCEN ‐ 7
FinCEN’s future plans will improve its ability to strengthen financial system security and 

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

BSA information, FinCEN will: 

• Modernize BSA information management and analysis to equip law enforcement 

and financial industry regulators with better decision-making abilities and 

increase the value of BSA information through increased data integrity and 

analytical tools. This multi-year program will: 

o Deploy advanced analytical and BSA data storage technologies; 

o Implement innovative Web-services and E-Filing technologies; 

o Enrich and standardize BSA data to maximize value for state and federal 

partners; 

o Integrate BSA data with other state and federal sources; 

o Deploy proven customer relationship technologies to capture data usage and 

access patterns and solicit/provide feedback to partners; 

o Establish effective data security and audit technologies to maximize BSA 

data confidentiality and integrity; and 

o Retire the current system of record (WebCBRS). 

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Section 2 – Budget Adjustments and Appropriation Language 

2.1 – Budget Adjustments Table 

Dollars in Thousands 

Financial Crimes Enforcement Network FTE Amount

FY 2010 Enacted 331 111,010

Changes to Base: 

Maintaining Current Levels (MCLs): - $1,656

FERS % Change - 104

Non-Pay Inflation Adjustment - 804

Pay Annualization - 192

Pay Inflation Adjustment - 556

Non-Recurring Costs: - ($8,250)

Non-Recur Funding - (8,250)

Efficiencies Savings: (4) ($3,997)

Efficiency Savings (4) (2,083)

IT and Procurement Savings - (1,914)

Subtotal FY 2011 Changes to Base (4) ($10,591)

Total FY 2011 Base 327 100,419

Total FY 2011 Budget Request 327 100,419

2A – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ........................................... +$1,656,000 / +0 FTE 

FERS % Change +$104,000 / +0 FTE 

Funds are requested for the increase in agency retirement contribution percentages for GS 

employees from 11.2% to 11.5% for FY 2011 as required by OPM. 

Non-Pay Inflation Adjustment +$804,000 / +0 FTE 

Funds are requested for non-pay related items such as inflation for contracts, travel, 

supplies, equipment and GSA rent. 

Pay Annualization +$192,000 / +0 FTE 

Funds are requested for the FY 2011 cost of the January 2010 pay raise. 

Pay Inflation Adjustment +$556,000 / +0 FTE 

Funds are requested for the January 2011 pay raise. 

Non-Recurring Costs ...................................................................... -$8,250,000 / +0 FTE 

Non-Recur Funding -$8,250,000 / +0 FTE 

Non-recur funding received in FY 2010 for the Information Technology (IT) 

Modernization initiative. FinCEN will seek alternate funding from the Treasury 

Forfeiture Fund to fully implement the planned IT Modernization. 

Efficiencies Savings .......................................................................... -$3,997,000 / -4 FTE 

Efficiency Savings -$2,083,000 / -4 FTE 

Reductions were identified as a result of business process efficiencies from consolidation 

of IT Infrastructure; expansion of shared services for administrative functions; reduction 

of discretionary travel and training; employee attrition savings; and other related savings. 

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FinCEN ‐ 10

IT and Procurement Savings -$1,914,000 / +0 FTE 

Savings were identified from a consolidation of commercial database contracts; spreading 

out investments for non-critical IT systems over a longer period; and reduction of other 

non-critical contractual services. 
2.2 – Operating Levels Table 

Financial Crimes Enforcement Network FY 2009 

Enacted

FY 2010 

President's 

Budget

Congression

al Action 

Including 

Rescission

FY 2010 

Enacted 

Level

Proposed 

Reprogram

mings

FY 2010 

Proposed 

Operating 

Level

FY 2011 

Requested 

Level

 

FTE 330 331 0 331 0 331 327

Object Classification: 

11.1 - Full-time permanent 33,092 34,453 0 36,108 0 36,108 37,130

11.3 - Other than full-time permanent 284 294 0 294 0 294 304

11.5 - Other personnel compensation 526 545 0 545 0 545 564

12 - Personnel benefits 9,030 9,075 0 9,420 0 9,420 9,597

21 - Travel and transportation of persons 1,216 1,153 0 1,153 0 1,153 844

23.1 - Rental payments to GSA 5,343 5,380 0 5,380 0 5,380 5,379

23.2 - Rental payments to others 70 71 0 71 0 71 71

23.3 - Comm, utilities, and misc charges 1,364 1,399 0 1,399 0 1,399 1,415

24 - Printing and reproduction 450 454 0 454 0 454 459

25.1 - Advisory and assistance services 1,815 1,830 0 1,829 0 1,829 1,849

25.2 - Other services 13,266 13,178 0 13,178 0 13,178 10,723

25.3 - Other purchases of goods and 14,198 14,445 0 14,545 0 14,545 14,595

services from Govt. accounts 

25.4 - Operation and maintenance of 960 968 0 968 0 968 737

facilities 

25.6 - Medical care 153 155 0 155 0 155 156

25.7 - Operation and maintenance of 5,003 5,056 0 5,056 0 5,056 5,118

equip 

26 - Supplies and materials 444 449 0 449 0 449 450

31 - Equipment 4,251 13,855 0 20,006 0 20,006 11,028

Total Budget Authority $91,465 $102,760 $0 $111,010 $0 $111,010 $100,419

 

Budget Activities: 

BSA Administration and Analysis 82,287 93,444 0 101,694 0 101,694 91,112

Regulatory Support Programs 9,178 9,316 0 9,316 0 9,316 9,307

Total Budget Authority $91,465 $102,760 $0 $111,010 $0 $111,010 $100,419

 

FinCEN ‐ 11
2.3 – Appropriations Detail Table 

Dollars in Thousands 

(Dollars in Thousands)

Resources Available for Obligation Obligations Enacted to FY 2011

FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

New Appropriated Resources:

BSA Administration and Analys 311 71,952 330 $82,287 331 $101,694 327 $91,151 -1.21% -10.37%

Regulatory Support Programs 8,647 9,178 9,316 9,268 -0.52%

Subtotal New Appropriated Resources 311 $80,599 330 $91,465 331 $111,010 327 $100,419 -1.21% -9.54%

Other Resources:

Recoveries 500 407 500 500

Offsetting Collections - Reimbursable 2 7,066 1 6,000 1 20,000 1 20,000 0.00% 0.00%

Available multi-year/no-year funds 14,330 14,300 20,526 18,138

Transfers In/Out 250 225 250 250

Subtotal Other Resources 2 $22,146 1 $20,932 1 $41,276 1 $38,888 0.00% -5.79%

Total Resources Available for Obligation 313 $102,745 331 $112,397 332 $152,286 328 $139,307 -1.20% -8.52%

% Change

FY 2009 FY 2009 FY 2010 FY 2011 FY 2010

Enacted Request

Appropriation Detail Table

2B – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes

DEPARTMENT OF THE TREASURY 

FINANCIAL CRIMES ENFORCEMENT NETWORK 

Federal Funds 

SALARIES AND EXPENSES: 

For necessary expenses of the Financial Crimes 

Enforcement Network, including hire of passenger motor 

vehicles; travel and training expenses, including for course 

development, of 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, [$111,010,000] 

$100,419,000 of which not to exceed $26,085,000 shall 

remain available until September 30, [2012] 2013; and of 

which [$9,316,000] $9,268,000 shall remain available until 

September 30, [2011] 2012: Provided, that funds 

appropriated in this account may be used to procure 

personal services contracts. 

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2C – Legislative Proposals 

FinCEN has no legislative proposals. 

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Section 3 – Budget and Performance Plan

This table lists all FY 2011 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 2010 

Enacted

FY 2011 

Request Percent Change

 U.S. & International Financial Systems 131,010 120,419 -8.08%

Total $131,010 $120,419 -8.08%

3A – BSA Administration and Analysis ($91,151,000 from direct appropriations and 

$20,000,000 from reimbursable programs): This activity comprises FinCEN’s efforts to 

administer the BSA, including promulgating regulations, providing outreach and issuing 

guidance to the regulated industries, providing oversight of BSA compliance, initiating 

enforcement actions, and, with the IRS, managing the information filed by the regulated 

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

AML regimes through training and technical assistance. Analytical programs include support to 

U.S. law enforcement and international FIUs in combating financial fraud and crime by 

facilitating the exchange of investigative information; identifying foreign and domestic financial 

fraud, money laundering, and terrorist financing trends, patterns, and techniques; and liaison with 

and support of intelligence initiatives within the intelligence community and within Treasury. 

This activity also incorporates efforts to support large-scale, complex law enforcement 

investigations involving financial fraud, terrorist financing, money laundering, and other 

financial crimes. 

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

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

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

establishing risk-based AML programs with appropriate policies, procedures, internal controls, 

and maintaining records and filing reports on certain types of financial activity pursuant to the 

BSA. As appropriate, FinCEN investigates alleged violations by financial institutions, issues 

letters of caution or warning, and seeks injunctions; additionally, when required, FinCEN 

imposes civil monetary penalties for egregious BSA violations, typically in conjunction with 

partner federal and state agencies. 

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

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

FinCEN ‐ 14
AML/CFT regulatory standards and norms; and improving the expertise and capabilities of 

personnel with AML/CFT missions. 

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

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

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

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

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

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 modernize the BSA information management and 

analysis to equip law enforcement and financial industry regulators with better decision-making 

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

analytical tools. 

Other Resources: Offsetting collections and reimbursements totaling $20,000,000 are collected 

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

assistance provided to international partners, and the Treasury Executive Office of Asset 

Forfeiture for projects to better support law enforcement. 

FinCEN ‐ 15
3.2.1 – BSA Administration and Analysis Budget and Performance Plan 

BSA Administration and Analysis Budget Activity

Resource Level

FY 2007 FY 2008 FY 2009 FY 2010 FY 2011

Obligated Obligated Obligated Enacted Request

 Appropriated Resources $64,780 $68,606 $82,287 $101,694 $91,151 

 Reimbursable Resources $0 $4,310 $6,000 $20,000 $20,000 

Total Resources $64,780 $72,916 $88,287 $121,694 $111,151

Budget Activity Total $64,780 $72,916 $88,287 $121,694 $111,151

BSA Administration and Analysis Budget Activity

Measure FY 2007 FY 2008 FY 2009 FY 2010 FY 2011

Actual Actual Actual Target Target

Average time to process enforcement matters (in Years) 1.1 0.7 1 1 1

(E) 

Median time taken from date of receipt of Financial 7 3 3 5 5

Institution Hotline Tip SARs to transmittal of the 

information to law enforcement or the intelligence 

community (E) 

Percentage of FinCEN's Regulatory Resource Center 91 94 94 90 90

Customers rating the guidance received as 

understandable (Oe) 

Percentage of FinCEN's compliance MOU holders NA 64 82 68 70

finding FinCEN's information exchange valuable to 

improve the BSA consistency and compliance of the 

financial system (Oe) 

Percentage of customers satisfied with the BSA E-Filing 94 93 94 90 90

(Oe) 

Percentage of domestic law enforcement and foreign 82 83 81 81 82

financial intelligence units finding FinCEN's analytical 

reports highly valuable (Oe) 

Percentage of federal and state regulatory agencies with NA 41 43 46 50

memoranda of understanding/information sharing 

agreements (Ot) 

Key: Oe - Outcome Measure, E - Efficiency Measure, and Ot - Output/Workload Measure 

In the regulatory area, FinCEN continues to increase activities to monitor financial institutions 

examined for BSA compliance by state and federal regulators through the establishment of 

Memorandums of Understanding (MOUs) to exchange compliance information with regulators. 

In 2009, FinCEN reached a level 43 percent of federal and state regulatory agencies with 

MOU/information sharing agreements, but did not meet its target of 45 percent. FinCEN 

finalized an MOU with the Commodity Futures Trading Commission, the last remaining federal 

regulator with BSA examination authority to sign an agreement and the Public Corporation for 

the Supervision and Insurance of Cooperatives in Puerto Rico. However, FinCEN was not able 

to execute three additional agreements at the state regulators. FinCEN will continue 

collaborating with state insurance agencies and other regulatory agencies to sign additional 

agreements to meet future targets. In FY 2009, FinCEN exceeded its target of 66 percent of 

MOU holders rating the information exchange valuable with 82 percent. FinCEN’s goal to 

provide financial institutions with understandable guidance is critical to institutions establishing 

AML programs that comply with the BSA. FinCEN exceeded its goal of 90 percent with 94 

percent of its customers rating the guidance received as understandable. FinCEN also works 

closely with its regulatory partners to take enforcement action against financial institutions that 

systemically and egregiously violate the provisions of the BSA, including imposing civil money 

FinCEN ‐ 16
penalties when appropriate. Timely enforcement action is essential to deter non-compliance with 

the BSA. In FY 2009, FinCEN met its target to process enforcement matters within 1 year. 

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

Intelligence Unit (FIU) partners by providing analyses of BSA information, and measures the 

percentage of customers finding FinCEN’s analytic reports highly valuable. The measure 

closely ties to how BSA information is used by law enforcement and international FIUs to 

identify, investigate, and prevent abuse of the financial system. In FY 2009, FinCEN met its 

target of 80 percent with 81 percent. 

To ensure the efficient management, safeguarding, and use of BSA information, FinCEN 

conducts a survey of the users of the BSA E-Filing system to determine the overall satisfaction 

level and to identify where improvements are needed. The FY 2009 target was to maintain at 

least a 90 percent satisfaction level, and FinCEN surpassed its target with 94 percent. 

3B – Regulatory Support Programs ($9,268,000 from direct appropriations): This activity 

supports implementation, strengthening and clarification of the AML program, recordkeeping, 

and reporting requirements of the BSA for financial institutions subject to those requirements. 

FinCEN will also continue efforts with the IRS, especially related to the MSB industry, to ensure 

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

and maintenance of the BSA data. These resources support IRS BSA compliance activities for 

non-banking financial institutions, especially related to the MSB industry. 

3.2.2 – Regulatory Support Programs Budget and Performance Plan 

Regulatory Support Programs Budget Activity

Resource Level

FY 2007 FY 2008 FY 2009 FY 2010 FY 2011

Obligated Obligated Obligated Enacted Request

 Appropriated Resources $8,436 $8,941 $9,178 $9,316 $9,268 

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

Total Resources $8,436 $8,941 $9,178 $9,316 $9,268

Budget Activity Total $8,436 $8,941 $9,178 $9,316 $9,268

As of November 17, 2009 the number of registered MSBs is 39,133. FinCEN expects to 

maintain or exceed this level by FY 2011 as a result of ongoing outreach efforts. 

FinCEN also continued to analyze SARs on a monthly basis for indications of possible 

unregistered MSBs, coordinate with law enforcement and state regulatory agencies on 

appropriate outreach, and educate MSBs on registration requirements by publishing guidance 

and participating in industry outreach events. 

Additionally FinCEN continued to work to improve the effectiveness and consistency of MSB 

examinations conducted by IRS and state examiners, by working on the development and 

delivery of MSB BSA/AML Examination Manual training, participating in a working group to 

FinCEN ‐ 17
develop joint examination procedures for IRS and state examiners, and participating in the 

development of a template for states to report quarterly examination data consistently to the IRS. 

 

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

validation, please go to: http://treas.gov/offices/management/budget/

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Section 4 – Supporting Materials 

4A – Human Capital Strategy Description 

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

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

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

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

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

perpetrators of financial crime. 

Organizational Effectiveness

The role of FinCEN as the nation’s FIU provides the bureau a unique view of the global 

economy. FinCEN recently completed an organizational realignment to elevate the international 

efforts to a division-level and demonstrate the emphasis the bureau places on safeguarding U.S. 

and international financial systems from abuse. 

FinCEN continues to rely upon the private sector to perform certain activities, primarily in the 

information technology environment. The FY 2009 FAIR Act Inventory was submitted to the 

Department in April 2009. 

Employee Retention and Satisfaction

In FY 2009, FinCEN implemented and invigorated several programs to improve employee 

morale. The Fitness Center Reimbursement Program and the Student Loan Repayment Program 

were introduced. FinCEN updated its Alternate Work Schedule Program and reinvigorated its 

Telework Program. 

Results from the 2008 Federal Human Capital Survey indicated that 81 percent of FinCEN 

employees know how their work relates to the agency’s goals and priorities, and 82 percent feel 

that they are held accountable for achieving results. 

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

performance management system requires that each employee be placed on performance 

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

performance management system allows managers to differentiate performance levels among 

employees and hold employees accountable for meeting specified performance goals and targets. 

Additionally, each employee works with his or her manager to agree upon an annual individual 

development plan to identify areas for career growth and development. 

FinCEN continues to maintain a robust Awards and Recognition Program, including an Annual 

Director’s Awards and Recognition Program. In FY 2008, 83 percent of the workforce was rated 

above the fully successful level and were appropriately recognized, while less than 1 percent was 

rated below fully successful and appropriate remedial actions were taken. 

FinCEN ‐ 19
Leadership and Workforce Planning

FinCEN leaders manage people and sustain an environment that drives continuous improvement 

in performance. FinCEN must also develop future leaders to prepare for the estimated 38 

percent of the workforce eligible to retire by 2013. 

In FY 2009, FinCEN launched an aggressive leadership development plan to strengthen the skills 

of its current leaders and promote leadership skills at all levels. Implementation included 360 

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

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

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

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

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

a range of topics available to all employees on a biweekly basis. Additionally, FinCEN 

sponsored five competitively-selected employees in long-term leadership development programs 

for grades 9-15, an annual opportunity. FinCEN also delivered in-house instruction to develop 

leadership skills in non-supervisors, and to empower all employees in accomplishing the 

bureau’s mission. 

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

Specialists, Regulatory Specialists and Law Enforcement Liaison Specialists. In FY 2009, 

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

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

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

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

and sharing expertise within and outside the bureau. In FY 2009, twelve highly qualified and 

motivated employees furthered their own learning and career development, while elevating 

communication and knowledge in their own rotational destinations. 

Recruitment and Diversity

FinCEN utilizes various hiring authorities and flexibilities. In 2009, 13 students were hired 

under the Student Temporary Employment Program (STEP). FinCEN utilized the Veterans 

Employment Opportunity Act (VEOA) and Schedule A Disability Appointment authority to 

make two appointments over the past two years. 

FinCEN reduced the amount of time it takes to hire employees from 45 days to 32 days during 

the last four quarters. 

FinCEN continued to take a number of steps to ensure a diverse workforce is maintained. It 

maintained its Diversity Advisory Committee, conducted a Diversity Day Training Conference 

for all employees, partnered with diverse academic groups to attract student interns of diverse 

background, and established contacts with special interest groups to attract applicants from 

diverse populations. FinCEN continued a mandatory Equal Employment Opportunity 

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FinCEN ‐ 21

(EEO)/Diversity element in all supervisory performance plans to address EEO principles, 

workplace conflict, supporting EEO plans and diversity hiring requirements. 

Employee Satisfaction and Wellness

FinCEN is in the process of developing an action plan in response to the 2008 Federal Human 

Capital Survey to improve communications, enhance a climate of support and trust, create a 

more positively engaged workforce, and improve working relations within each employee level 

and across the organization. The plan will include specific actions to be taken, timeframes for 

completion, and resource needs for implementation, including an evaluation component to 

determine whether the plan is effective in reaching target outcomes. 

FinCEN has already started gathering data in order to respond to the Office of Personnel 

Management’s call for an inventory of current wellness activities, cafeteria and fitness facilities, 

and health clinics. FinCEN’s D.C. and Vienna locations both have access to Health units with 

onsite nursing staff, and Vienna has an onsite fitness center (employees pay fitness center fee). 

In January 2009, FinCEN implemented a Fitness Center Reimbursement Program; 70 employees 

(22 percent) are participating in the reimbursement program for a total cost of $18,630 in support 

of employee health and wellness. FinCEN also has a Worklife Coordinator to promote the 

Employee Assistance Program and Resources and Referral Service, WorkLife4You, which 

provide free services to employees. FinCEN also provides informational emails and seminars to 

employees on physical and mental health and wellness issues. 

FinCEN offers employees both Alternate Work Schedules (AWS) and Telework programs. 

Results from the 2008 Federal Human Capital Survey indicated that 77 percent of FinCEN 

employees are satisfied with AWS and 84 percent feel that their manager supports their needs to 

balance work and other worklife issues. In addition, 51 percent are satisfied with FinCEN 

worklife programs, which is an increase from 35 percent in 2006. 
4.1 – Summary of IT Resources Table 

Dollars in Thousands 

FY 2007 FY 2008 FY 2009 FY 

Major IT Investments / Funding Source Budget Activity Enacted Enacted Request En

BSA Information Technology Modernization 

Total Major IT Investments BSA Administration and Analysis 0 0 0 

Total Non-Major IT Investments BSA Administration and Analysis 11,424 17,273 18,108 Total Infrastructure Investments BSA Administration and Analysis 8,474 9,711 9,800 Total Enterprise Architecture BSA Administration and Analysis 203 385 385 Total IT Investments BSA Administration and Analysis 20,101 27,369 28,293 

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4B – Information Technology Strategy 

As the administrator of the BSA, FinCEN is entrusted to receive valuable information 

reported and collected under BSA requirements, which was approximately 17 million 

filings in FY 2009. The bureau’s mission is to enhance U.S. national security, deter and 

detect criminal activity, and safeguard financial systems from abuse by promoting 

transparency in the U.S. and international financial systems. FinCEN’s mission supports 

Treasury’s strategic goal to prevent terrorism and promote the nation’s security through 

strengthened financial systems. To successfully fulfill its mission, FinCEN relies on 

secure, advanced information technology (IT) to manage the collection, processing, 

storage, and dissemination of BSA information that contributes to the soundness and 

confidence in America’s financial system. 

FinCEN’s IT Strategy takes into account the growing need to reduce the obligations on 

the financial institutions, while ensuring that National and global law enforcement 

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

identify money laundering, and unravel terrorist financing networks. FinCEN’s IT 

Strategy focuses on the critical need to improve the quality and accessibility of its data 

and increase responsiveness to stakeholders by introducing flexible and innovative 

technical solutions. 

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

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

Strategy, which serves as the roadmap for aligning its IT portfolio with its business 

objectives and processes and has resulted in the multi-year BSA IT Modernization 

program. By establishing an enterprise-wide information management and analysis 

framework, law enforcement and financial industry regulators will be equipped with 

better decision-making abilities and increased value of BSA information through 

enhanced data integrity and analytical tools. This will allow law enforcement and 

regulators to focus their limited resources on the areas of shifting illicit criminal activities 

and vulnerabilities effecting the soundness and stability of the U.S. financial system. 

The Modernization Program also focuses on simplifying stakeholder interaction for filing 

and information dissemination, as well as reducing operation and maintenance costs by 

employing best-in-class technology solutions to connect people, processes, and 

information. 

Treasury is currently developing the plan for developing the modernized system, retiring 

the legacy system, and providing an overview of the detailed technical alternatives being 

considered to stakeholders. Also, in FY2009, FinCEN completed the program initiation 

work, which included documenting program management processes, business needs, and 

IT solution development direction for the full BSA IT Modernization program. 
4.2 – Program Evaluation 

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

Assessment and Improvement Actions 

• 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 and published by 

FinCEN. In Q3 FY 2009 FinCEN implemented Adobe Forms for E-Filing and in Q4 

FY 2009 FinCEN implemented the SAR acknowledgment functionality; these actions 

also support Treasury’s paperless initiative. 

• 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 

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

established a process for updating and tracking these issues. In Q4 FY 2009 there were 

203 closed data quality issues. 

• 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. In Q2 FY 2009 FinCEN developed a MSB 

page on the current FinCEN public web site intended to replace MSB.gov. In Q3 and 

Q4 FY 2009 FinCEN is researching technical web-based alternatives. In Q4 FY 2009 

a web based presentation tool was tested and purchased that met FinCEN’s 

requirement for internal and external web based presentation needs without requiring 

the IT forums. 

FinCEN ‐ 24
Program Name: Bank Secrecy Act (BSA) Analysis 

Assessment and Improvement Actions 

• Working to provide better understanding of FinCEN’s analytical products and 

services to law enforcement customers, to better meet its customer's needs, and create 

a process for assessing and prioritizing requested products and services. FinCEN has 

drafted a concept of operations document that outlines this process and has begun 

internal meetings to solicit feedback on the proposal. In FY 2009, FinCEN continued 

an ongoing management review on this process. 

FinCEN ‐ 25
FinCEN ‐ 26

Program Name: Bank Secrecy Act (BSA) Administration 

Assessment and Improvement Actions 

• Streamline regulatory requirements and other modifications relating to money 

services businesses subsequent to a review of existing regulatory framework and 

current issues. For FY 2009, FinCEN published a Notice of Proposed Rulemaking 

(NPRM) to revise the money services business rules. 

• Expand information sharing agreements with federal and state regulators, with a focus 

on insurance commissioners. The MOU is an essential step to obtaining the data to 

monitor compliance and examination of covered industries. FinCEN uses this 

information to help its efforts to better ensure consistent examination procedures and 

standards. The MOUs also must be expanded to state regulators covering the 

banking, securities, insurance, money services business, and gaming industries to 

provide consistency of application across these financial sectors. For FY 2009, 

FinCEN developed a strategy that outlines the steps needed to begin the 

implementation of information sharing agreements with state insurance departments. 

The strategy includes the drafting of a template for MOUs, obtaining information 

from state/territory insurance commissioners, and gaining a better understanding of 

the state insurance examination process. In Q2 FY 2009 FinCEN determined that 129 

regulatory bodies examine for BSA compliance in the insurance industry and a 

Memoranda of Understanding was signed with the Commodity and Futures Trading 

Commission. In Q4 FY 2009 FinCEN identified additional companies for outreach 

and visits are being arranged.