Department of the Treasury 

Financial Crimes Enforcement 

Network 

Congressional Budget 

Justification and Annual 

Performance Plan and Report 

FY 2022 
FinCEN - 2 

Table of Contents

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

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

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

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

1.2 – Budget Adjustments Table ................................................................................................. 4

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

1.3 – Object Classification (Schedule O) Obligations ................................................................ 7

D – Appropriations Language and Explanation of Changes ...................................................... 8

E – Legislative Proposals ............................................................................................................ 8

Section II – Annual Performance Plan and Report ................................................................... 9

A – Strategic Alignment ............................................................................................................. 9

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

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

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

C – Evidence-Building Activity ................................................................................................ 15

Section III – Additional Information ........................................................................................ 19

A – Summary of Capital Investments ....................................................................................... 19

 
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Section I – Budget Request 

A – Mission Statement 

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

national security through the strategic use of financial authorities and the collection, analysis, 

and dissemination of financial intelligence. 

B – Summary of the Request 

The FY 2022 President’s Budget requests additional resources totaling $63,576,000 providing 

$60,279,000 for the implementation of the Anti-Money Laundering Act/Corporate Transparency 

Act (AMLA/CTA) of the William M. (Mac) Thornberry National Defense Authorization Act 

(NDAA) for Fiscal Year (FY) 2021 and $87,000 for the leasing of electric vehicles and purchase 

of associated infrastructure. 

1.1 – Appropriations Detail Table 

Dollars in Thousands 

 FY 2020 FY 2021 FY 2022 FY 2021 to FY 2022 

Appropriated Resources Operating Plan Operating Plan Request % Change 

New Appropriated Resources FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

BSA Administration and Analysis 264 $126,000 300 $126,963 380 $190,539 26.7% 50.1% 

Subtotal New Appropriated 

Resources 264 $126,000 300 $126,963 380 $190,539 26.7% 50.1% 

Other Resources 

Reimbursable 1 $1,613 3 $6,000 3 $6,000 0.0% 0.0% 

Recoveries from Prior Years 0 $143 0 $0 0 $0 NA NA 

Unobligated Balances from Prior 

Years 0 $26,416 0 $29,000 0 $29,000 NA 0.0% 

Subtotal Other Resources 1 $28,172 3 $35,000 3 $35,000 0.0% 0.0% 

Total Budgetary Resources 265 154,172 303 $161,963 383 $225,539 26.4% 39.3% 

FY 2020 Other Resources and Full-time Equivalents (FTE) reflect actuals. 
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1.2 – Budget Adjustments Table 

Dollars in Thousands 

 FTE Amount 

FY 2021 Operating Plan 300 $126,963 

Changes to Base: 

Maintaining Current Levels (MCLs): 0 $3,210 

Pay Annualization (1.0% average pay raise) 0 $137 

Pay Raise (2.7% average pay raise) 0 $1,109 

FERS Contribution Increase 0 $517 

Non-Pay 0 $1,447 

Subtotal Changes to Base 0 $3,210 

FY 2022 Current Services 300 $130,173 

Program Changes: 

Program Increases: 80 $60,366 

FinCEN AMLA/CTA Implementation* 80 $60,279 

Purchase of Electric Vehicles and Associated Infrastructure 0 $87 

FY 2022 President's Budget Request 380 $190,539 

*Amounts shown reflect enacted appropriations for 2021, which do not include dedicated funding for 

development of the beneficial ownership data system and CTA implementation. However, FY 2022 staffing 

does assume funding, yet to be identified, is provided for this purpose in 2021. FY 2022 staffing does assume 

funding, yet to be identified, is provided for this purpose in 2021. FinCEN estimates a total of 131 new 

positions will be needed for full implementation of the CTA and Anti-Money Laundering Act (P.L. 116-283). 

C – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ......................................................... +3,210,000 / +0 FTE 

Pay Annualization (1.0%) +137,000 / +0 FTE 

Funds are requested for annualization of the January 2021 1.0% average pay raise. 

Pay Raise (2.7% in 2022) +$1,109,000 / +0 FTE 

Funds are requested for a 2.7% average pay raise in January 2022. 

FERS Contribution Increase +$517,000 / +0 FTE 

Funds are requested for the Federal Employee Retirement System (FERS) contribution rates 

effective FY 2022. 

Non-Pay +$1,447,000 / +0 FTE 

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

and equipment. 

Program Increases ................................................................................. +$60,366,000 / +80 FTE 

FinCEN AMLA/CTA Implementation +$60,279,000 / +80 FTE 

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

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

regime through the AMLA and the CTA. 

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

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

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

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

identify risks and priorities and provide valuable feedback to our industry partners. 
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Within the AMLA, the CTA establishes uniform beneficial ownership reporting requirements for 

corporations, limited liability companies, and other similar entities formed or registered to do 

business in the United States. The CTA provides FinCEN with the authority to collect that 

information and share it with authorized government authorities and financial institutions, 

subject to effective safeguards and controls. To that end, FinCEN will use this funding to 

develop and maintain a data system for the reporting of information on beneficial ownership, 

collecting and securing the data, and creating access protocols. 

The AMLA and the CTA together set forth approximately 40 rulemaking or other requirements, 

including periodic Congressional reporting on implementation efforts, assessments, and 

findings. Some key requirements include: 

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

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

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

priorities; 

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

new anti-retaliation protections; 

4. Reviewing, and revising as appropriate, Currency Transaction Report (CTR) and Suspicious 

Activity Report (SAR) reporting requirements, and other existing Bank Secrecy Act (BSA) 

regulations and guidance; 

5. Expanding BSA requirements and obligations to persons engaged in the trade of antiquities, 

and mandating a study on the potential expansion of BSA requirements to persons engaged in 

the art trade; 

6. Codifying the FinCEN Exchange program; 

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

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

technology as well as information security; 

8. Establishing a BSA Analytical Hub; 

9. Law enforcement reporting to FinCEN on the use of BSA data, procedures for additional 

feedback between FinCEN and financial institutions on the usefulness of SARs, and semiannual publication of review of SAR activity and other BSA reports, including threat 

patterns, trends, and typologies; and 

10. Codifying a pilot program to allow financial institutions to share SARs with their foreign 

branches, subsidiaries, and affiliates. 

Timely and effective AMLA and CTA implementation will be challenging and is FinCEN’s top 

priority, and we are working diligently with our domestic and international industry partners and 

law enforcement and regulatory stakeholders to implement these numerous provisions to further 

the national security and innovative strength of the United States and protect the American 

people. 

The January 1, 2021, enactment of the AMLA and CTA did not come with accompanying 

funding, and FinCEN has been diverting existing resources to meet the rigorous deadlines set 

forth in the legislation. Therefore, in order to meet this new, expansive statutory mandate, 
FinCEN - 6 

FinCEN requests this significant program increase to fund the FTE positions and information 

technology systems needed to effectively implement the AMLA and CTA. 

Purchase of Electric Vehicles and Associated Infrastructure +$87,000 / +0 FTE 

Following the lead from Executive Order (E.O.) 14008, “Tackling the Climate Crises at Home 

and Aboard”, the U.S. Department of the Treasury joins in the Administration’s priority to 

develop a comprehensive plan to create good jobs and stimulate clean energy industries by 

revitalizing the Federal Government’s sustainability efforts. This includes Treasury’s 

commitment to use all available procurement authorities to augment its Department-wide fleet 

management program with a continued focus on the leasing of electric vehicles (EV) and 

purchasing, installing, and maintaining essential infrastructure. The planned resources will help 

Treasury comply with the requirements set forth by E.O. 14008 and reduce the carbon footprint 

of emissions into the atmosphere by acquiring an updated fleet of zero-emissions vehicles that 

can support mission operations. 

For FY 2022, the Financial Crimes Enforcement Network (FinCEN) will receive $87,000 to fund 

the full conversion of its fleet to EV. Of that money, approximately $25,000 will be allocated to 

the purchase, installation, maintenance, and/or upgrade of infrastructure required to maintain an 

EV fleet management program. Additionally, FinCEN will purchase one additional charging 

station to support its future EV state. Currently, FINCEN has a total of four vehicles in its fleet, 

of which two are EVs. 
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1.3 – Object Classification (Schedule O) Obligations 

Dollars in Thousands 

 FY 2020 FY 2021 FY 2022 

Object Classification 

Actual 

Obligations 

Estimated 

Obligations 

Estimated 

Obligations 

11.1 - Full-time permanent 35,409 41,247 51,975 

11.3 - Other than full-time permanent 409 150 150 

11.5 - Other personnel compensation 1,032 845 845 

11.8 - Special personal services payments 5 0 0 

11.9 - Personnel Compensation (Total) 36,855 42,242 52,970 

12.0 - Personnel benefits 12,093 12,799 15,479 

Total Personnel and Compensation Benefits $48,948 $55,041 $68,449 

21.0 - Travel and transportation of persons 276 816 1,155 

23.1 - Rental payments to GSA 4,570 4,971 4,971 

23.2 - Rental payments to others 29 51 3,192 

23.3 - Communications, utilities, and miscellaneous charges 2,508 2,137 2,187 

24.0 - Printing and reproduction 62 65 67 

25.1 - Advisory and assistance services 1,588 1,552 9,938 

25.2 - Other services from non-Federal sources 40,984 46,638 76,570 

25.3 - Other goods and services from Federal sources 8,972 10,143 12,939 

25.4 - Operation and maintenance of facilities 1 0 0 

25.6 - Medical care 200 226 231 

25.7 - Operation and maintenance of equipment 8,878 9,497 9,718 

26.0 - Supplies and materials 351 278 324 

31.0 - Equipment 7,187 1,928 6,798 

32.0 - Land and structures 5 0 0 

Total Non-Personnel $75,611 $78,302 $128,090 

Total Obligations $124,559 $133,343 $196,539 

 

Full-time Equivalents (FTE) 265 303 383 

Amounts reflect actual and anticipated obligations of annually appropriated resources and reimbursables. 
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D – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes 

DEPARTMENT OF THE TREASURY 

FINANCIAL CRIMES ENFORCEMENT NETWORK 

Federal Funds 

SALARIES AND EXPENSES 

For necessary expenses of the Financial Crimes Enforcement 

Network, including hire of passenger motor vehicles; travel and 

training expenses of non-Federal and foreign government 

personnel to attend meetings and training concerned with 

domestic and foreign financial intelligence activities, law 

enforcement, and financial regulation; services authorized by 5 

U.S.C. 3109; not to exceed [$12,000]$45,000 for official 

reception and representation expenses; and for assistance to 

Federal law enforcement agencies, with or without 

reimbursement, [$126,963,000]$190,539,000 of which not to 

exceed [$34,335,000]$94,600,000 shall remain available until 

September 30, [2023]2024 for information technology and to 

implement Division F of the William M. (Mac) Thornberry 

National Defense Authorization Act for Fiscal Year 2021 

(Public Law 116-283). (Consolidated Appropriations Act, 2021, 

Public Law 116-260) 

Changes to the 

appropriations language 

represent the additional 

amount for necessary 

expenses of the Financial 

Crimes Enforcement 

Network for the 

implementation of 

Division F of the William 

M. (Mac) Thornberry 

National Defense 

Authorization Act for 

Fiscal Year 2021 (Public 

Law 116-283).

E – Legislative Proposals 

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

A – Strategic Alignment 

In accordance with the Government Performance and Results Act Modernization Act 

(GPRAMA) of 2010, the Department of the Treasury is currently developing the FY 2022 – 

2026 Departmental Strategic Plan. The Strategic Plan is scheduled for publication in 2022. The 

Annual Performance Plan will be updated in the FY 2023 President’s Budget to reflect new 

departmental strategic goals and objectives. FinCEN will publish a component plan that aligns 

bureau activities and priorities to the Department’s by early 2022. 

In FY 2020, FinCEN has had several noteworthy accomplishments highlighted below: 

Modernize, Streamline, and Simplify Regulatory Authorities: FinCEN made significant 

progress with respect to advancing regulatory initiatives impacting the AML framework this 

year. 

 FinCEN issued an Advance Notice of Proposed Rulemaking (ANPRM) seeking comment on 

the AML program effectiveness in order to provide financial institutions its greater flexibility 

in the allocation of resources and enhance the effectiveness and efficiency of AML programs. 

 FinCEN issued two Notices of Proposed Rulemaking (NPRM) related to virtual currency and 

to proposed reductions in the recordkeeping requirements for cross-border funds transmittals. 

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

and beneficial ownership requirements for banks lacking a federal functional regulator. 

 FinCEN drafted and coordinated numerous significant guidance documents: (1) Politically 

Exposed Persons (PEP) statement (August 21), (2) FinCEN Enforcement of the BSA (August 

18, (3) FAQs Regarding Customer Due Diligence Requirements for Covered Financial 

Institutions (August 3), (4) Guidance Regarding Due Diligence Requirements under the BSA 

for Hemp-Related Business Customers (June 29), (5) Clarification of Requirements for 

Providing Financial Services to Hemp-related Businesses (December 3, 2019), and (6) Joint 

Statement of FinCEN, SEC, and CFTC on Activities Involving Digital Assets (October 11, 

2019); and (7) a new Fact Sheet providing clarification on FinCEN’s information sharing 

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

 Published another three advisories associated with the result of the Financial Action Task 

Force decisions on countries with problematic AML/CFT regimes (July 14, 2020, March 26, 

2020, and November 12, 2019). 

 The results of the multi-year BSA Value Study, which provided the valuable insights into the 

use and value of BSA reporting (including a quantification of the estimated annual value to 

American public welfare of BSA data), was initially shared at the May 2020 BSAAG 

Plenary. 

COVID 19: FinCEN took a whole of agency approach to tackling the COVID-19 pandemic and 

illicit finance threats that it generated. Among other things, FinCEN: 

 Issued Notices to financial institutions—one on March 16, one on April 3, and another on 

May 18—advising them to remain alert to fraudulent, COVID-19 related transactions, and 
FinCEN - 10 

providing instructions on BSA filing requirements. Most recently, FinCEN issued a notice 

on December 28, to alert financial institutions about the potential for fraud, ransomware 

attacks, or similar types of criminal activity related to COVID-19 vaccines and their 

distribution. 

 Published three advisories related to COVID-19 medical fraud (May 18), imposter scams 

(July 7), and cyber-enabled crime (July 30), and defrauding of the unemployment insurance 

system (and reissued each one in Spanish) and one Alert related to fraud conducted through a 

hack of Twitter accounts (July 16). Issued Frequently Asked Questions in connection with 

the Coronavirus Aid, Relief, and Economic Security (CARES) Act Paycheck Protection 

Program (PPP), to clarify the applicability of beneficial ownership information collection 

requirements to PPP loans. 

 Responded to approximately 750 incoming queries related to the implementation of the 

CARES Act and its intersection with the BSA. 

 FinCEN quickly expanded its Rapid Response Program, which assists law enforcement in the 

recovery of funds stolen via fraud and business email compromise to include requests related 

to COVID-19. Since the beginning of the pandemic, FinCEN has supported several requests 

from federal, state, and international law enforcement agencies, aiding in the successful 

recovery of almost $325 million stolen in COVID-19 related fraud by illicit actors around the 

world. 

 Continued to host Innovation Hours meetings with Financial Technology, Regulatory 

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

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

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

FinCEN held ten monthly sessions during FY 2020 (of which five were held virtually in light 

of the pandemic) and one special regional event in New York in partnership with the Office 

of the Comptroller of the Currency in November 2019. 

Expand Supervision over Non-bank Financial Institutions (NBFIs):

 Led or participated in three examinations of NBFIs. 

 Conducted the first FinCEN-only examination of compliance with a Geographical Targeting 

Order, including the development of attendant policies and procedures (this also represented 

FinCEN's first examination of a title insurance company). 

Enhance Systems and Analytical Capabilities:

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

on BSA reports information and transaction data. 

Expand Special Measures Efforts:

 In October 2019, FinCEN found Iran to be a jurisdiction of primary money laundering 

concern under Section 311 of the USA PATRIOT Act and issued a regulation prohibiting the 

opening or maintaining of correspondent accounts in the United States for, or on behalf of, 

Iranian financial institutions, and the use of foreign financial institutions’ correspondent 
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accounts at covered U.S. financial institutions to process transactions involving Iranian 

financial institutions.

 On August 10, 2020, FinCEN withdrew the 2005 Notice of Finding and repealed the 2007 

Final Rule against Banco Delta Asia, S.A.R.L., Delta Asia Group Ltd. imposing Special 

Measure 5 under Section 311 of the USA PATRIOT Act. 

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

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

orders) on major illicit finance issues around the world. 

Financial Intelligence:

 Developed at least 58 tactical and strategic intelligence products for law enforcement and 

other interagency partners that track the illicit financial flows associated with cybercrime and 

cyber-enabled threats. 

 Published nine products to FinCEN’s Secure Information Sharing System portal for industry 

and law enforcement, containing more than 23,000 unique cyber indicators derived from 

BSA data. 

 Produced six strategic or tactical Intelligence Assessments, nine Network Analyses, and eight 

Investigative Memos profiling terrorist threats. 

 Produced monthly and weekly assessments of terrorism financing trends and reports 

supporting specific law enforcement investigations. 

Expand Threat and Information Sharing:

 Hosted two virtual FinCEN Exchange events to enhance information sharing with and 

provide feedback to financial institutions: a November 2020 Exchange focused on 

ransomware detection and reporting, emerging trends and typologies, and recovery of victim 

assets and a March 2021 Exchange focused on providing trends and statistics regarding lowdollar, voluntarily-filed Suspicious Activity Reports. 

 Led various Egmont Group projects, to include a project focused on the role of financial 

intelligence units in detecting human trafficking illicit flows through the misuse of virtual 

assets and a webinar focused on virtual assets and the role of financial intelligence units, law 

enforcement, and prosecutors. 

 In addition to expanding the Rapid Response Program (RRP) as mentioned above to assist in 

the recovery of COVID-19 related fraud, FinCEN launched two pilot programs to handle all 

RRP referrals regardless of the crime or monetary threshold and on domestic wire transfers 

related to business email compromise. From FY20 to the present, the RRP processed over 

1150 referrals, involving over $867 million in allegedly fraudulently stolen funds and 

assisting in the recovery of over $525 million. 

FinCEN’s FY 2021 and FY 2022 Priorities include: 

 Timely and effectively implementing the AMLA/CTA, including: 1) the design and 

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

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

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

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

numerous other provisions requiring coordination, collaboration with and feedback to law 
FinCEN - 12 

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

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

provisions. 

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

recovery, rising domestic violent extremism, AMLA/CTA implementation, interference from 

foreign state actors, and a new Administration. This includes an emphasis on advancing the 

innovative strength of the U.S. financial system, financial inclusion, and countering abuse by 

malign state actors and domestic terrorists, as well as corporate and political corruption that 

undermine the integrity and opportunity of the financial system, beyond the prior, post-9/11 

emphasis on foreign terrorists. FinCEN also was prescient in seeking to develop cyber and 

cryptocurrency capabilities for the past few years despite resource limitations, but threats 

related to those issues have grown faster than our resourcing (people and technology) and the 

demand from Treasury and the National Security Council, so those need to be addressed 

deliberately. 

 Filling FinCEN’s vacancies, continue training and developing our workforce and leadership 

teams, and continue to improve our technology. 
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B – Budget and Performance by Budget Activity 

2.1.1 – BSA Administration and Analysis Resources and Measures 

Dollars in Thousands 

 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 FY 2022 

 Resource Level Actual Actual Actual Actual Actual Operating 

Plan Request 

Appropriated Resources $112,979 $115,003 $115,003 $117,800 $126,000 $126,963 $190,539 

Reimbursable Resources $1,721 $2,526 $2,198 $1,771 $1,613 $6,000 $6,000 

Budget Activity Total $114,700 $117,529 $117,201 $119,571 $127,613 $132,963 $196,539 

Full-time Equivalents (FTE) 279 275 281 273 265 303 383 

The FY 2016 - FY 2020 appropriated resources represents the approved operating plan. The FY 2016 - FY 2020 columns represent realized 

resources for full-time equivalents, reimbursables, and user fees. 

Workload 

Output/Activity 

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2020 FY 2021 FY 2022 

Actual Actual Actual Actual Actual Estimate Estimate Estimate 

Number of SARs filed 2,316,550 2,401,896 2,537,225 2,698,841 3,039,421 2,779,806 2,863,200 2,949,096 

Number of total BSA 

reports filed 19,244,824 19,322,891 20,393,947 20,755,285 20,051,834 21,170,391 21,593,799 22,025,674 

Number of BSA users 10,833 11,452 11,739 12,801 13,047 

13,185 

 

13,581 

 

13,852 

Performance Measure 

FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2020 FY 2021 FY 2022 

Actual Actual Actual Actual Actual Target Target Target 

Percentage of Domestic 

Law Enforcement and 

Foreign FIUs who Assert 

Analytic Products Used 

Led to Detection and 

Deterrence of Illicit 

Activity 

95% 92% 95% 92% 97% 90% 90% 90% 

Percentage of Domestic 

Law Enforcement and 

Regulators Who Assert 

Queried BSA Data Led 

to Detection and 

Deterrence of Illicit 

Activity 

83% 86% 85% 92% 90% 88% 89% 90% 

Percentage of Users 

Satisfied with FinCEN 

Information Sharing 

Systems 

80% 87% 86% 89% 88% 84% 85% 85% 

BSA Administration and Analysis Budget and Performance 

($190,539,000 from direct appropriations, $6,000,000 from reimbursable sources)

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

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

two primary roles in the national security apparatus: 1) administrator and primary regulator of 

the BSA, and 2) Financial Intelligence Unit for the United States. In carrying out its mission, 

FinCEN has numerous statutory areas of responsibility: 

 Developing and issuing regulations under the BSA; 

 Developing and issuing regulations pursuant to the CTA, including the development of the 

information technology system for beneficial ownership data; 

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

regulatory partners; 
FinCEN - 14 

 Serving as the U.S. Financial Intelligence Unit (FIU) and maintaining a network of 

information sharing with FIUs in 164 partner countries; 

 Receiving millions of new financial reports each year; 

 Securing and maintaining a database of over 300 million reports; 

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

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

 Bringing together the disparate interests of law enforcement, FIUs, regulatory partners, and 

industry. 

Description of Performance: 

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

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

FinCEN’s performance safeguarding the financial system from illicit use, combatting money 

laundering, and promoting national security. 

The first performance measure is the percentage of domestic law enforcement and foreign FIUs 

who assert analytic products led to the detection and deterrence of illicit activity. This 

performance measure tracks what the analytics products are intended to do, i.e., be useful to a 

wide range of customers and have impact, such as identifying new leads or provide previously 

unknown information. In FY 2020, 97 percent found the analytic products and research had 

impact on the investigations, meeting the target of 90 percent or above. FinCEN was able to 

achieve this high level of performance by continuously improving processes to increase and 

rapidly disseminate intelligence reports to a wider audience, maintaining the high quality of its 

reporting through stringent review processes, and covering issues and topics that meet the 

operational and intelligence demands of its domestic and international stakeholders. For 

example, in FY 2020, FinCEN integrated the dissemination function into the Intelligence 

Division, which streamlined the dissemination process and improved communications between 

analysts, operations support, and customers. FinCEN also increased dissemination of its 

domestic intelligence products by increasing the number of products posted on the FinCEN 

Portal and on FinCEN’s public website and by highlighting certain reports on the main page of 

the Portal. This process resulted in greater and more informative feedback from customers. 

Also, by reducing the average response time for completing these requests by 14 days, and by 

working more closely with U.S. law enforcement and Treasury components to resolve 

deconfliction issues, FinCEN has been able respond to international requests at a faster rate. In 

FY 2021 and FY 2022, the target is set at 90 percent and above. 

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

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

looks at the value of FinCEN data, such as whether the data provided unknown information; 

supplemented or expanded known information; verified information; helped identify new leads; 

opened a new investigation or examination; supported an existing investigation or examination; 

or, provided information for an investigative or examination report. In FY 2020, FinCEN 

surpassed its target of 88 percent with 90 percent asserting the queried BSA data led the 

detection and deterrence of illicit activity. FinCEN achieved this performance by expanding its 

FinCEN Portal and Query training efforts and supplementing that training by posting useful, 

mission-oriented material on FinCEN Portal. In FY 2021, FinCEN will continue to expand its 
FinCEN - 15 

training efforts and content to provide the FinCEN Portal and FinCEN Query user community 

with the information they need to successfully enhance their investigative efforts. In FY 2021, 

the target is set at 89 percent and in FY 2022 at 90 percent. 

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

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

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

other filers. In turn, FinCEN provides authorized users (including Treasury and TFI) access to a 

query system containing 15 years of BSA data. FinCEN also provides foreign FIUs in the 

Egmont Group with a secure system for exchanging financial intelligence to combat money 

laundering and terrorist financing. This measure is meaningful because the technology allows 

authorized persons to access BSA information more readily and better enables them to conduct 

investigations more efficiently and effectively. In FY 2020, FinCEN exceeded its target of 84 

percent with 88 percent of the users satisfied with information sharing systems. FinCEN 

attributes the increase to specific customer service support provided to the Egmont Group with 

tasks, such as improving the content management organization and how users access much of the 

content within the ESW. FinCEN recently completed a technology refresh of ESW and is 

targeting a refresh of the FinCEN Portal and Query applications in FY 2021. These efforts will 

make significant updates to the underlying technologies and bring about some enhanced 

capabilities to the user community for the Portal/Query Applications. Since we anticipate 

somewhat of a learning curve associated with these updates, the targets are set at 85 percent for 

FY 2021 and FY 2022. 

C – Evidence-Building Activity 

The BSA Value Project provided FinCEN with a methodology and initial calculation of the value 

of BSA reporting. The Project information and final results (1) informed and helped measure the 

potential impact of proposed regulatory reform actions, including regulatory or compliance 

changes; (2) established a greater public understanding of how BSA reporting is used; (3) 

supported the development of more targeted feedback to financial institutions on the use and 

value of their reporting; (4) identified additional measures or actions that FinCEN and other 

stakeholders can take to improve the tracking and calculation of BSA reporting value; and (5) 

identified actions that can enhance the underlying value and use of BSA reporting. 

FinCEN also conducts research for its guidance and regulations. FinCEN worked closely with 

its Congressional, Main Treasury, and interagency partners on the AMLA/CTA legislation 

passed as part of the FY 2021 NDAA which made sweeping, positive changes to the AML 

system, including the creation of a beneficial ownership registry. Implementation of this 

legislation will occur over several years. 

The table below describes FinCEN’s major evidence-building activities and corresponding 

resources. Additionally, refer to the Executive Summary for a discussion of Treasury-wide 

evidence-building functions. 
FinCEN - 16 

Type of 

Evidence 

Building 

Activity 

Major Activities and Planned 

Projects

Resource Types Use 

Evaluation 

Collection and 

analysis of data 

to assess 

effectiveness and 

efficiency of 

programs, 

policies, or 

procedures

Estimated share 

of all EvidenceBuilding 

Activities:

 20 %

Major activities: 

 Implementation of the Anti-Money 

Laundering (AML) Act of 2020, 

including the Corporate 

Transparency Act through the 

issuance of guidance and regulations 

required by the legislation, as well as 

create a functional beneficial 

ownership information system. 

 Modernize, Streamline, and Simplify 

Regulatory Authorities 

 Review of Rapid Response Program 

(RRP) requests, responses, recovery 

rates, and other data to determine 

effectiveness and efficiency of 

program, and potential trends. 

 23 PD FTEs in 

FY 2020, Series 

0301 

 SOD 1 FTE in 

FY 2021, Series 

0301 and 

approximately 3 

firm, fixedprice 

contractors. 

☒ For internal 

policy decisionmaking 

☒ During internal 

strategic 

management 

processes 

☒ By external 

partners 

(government) 

☒ By external 

partners (nongovernment) 

☐ By unaffiliated 

external 

researchers 

☐ Other (describe) FY21 and FY22 projects: 

 Implement the AML Act of 2020, 

including the Corporate 

Transparency Act through the 

issuance of guidance and regulations 

required by the legislation 

 Modernize, Streamline, and Simplify 

Regulatory Authorities 

 Review of RRP requests, responses, 

recovery rates, and other data to 

determine effectiveness and 

efficiency of program, and potential 

trends. 

Research 

Modeling or 

other systematic 

use of data to 

explore emerging 

issues or 

potential 

scenarios to 

generate new 

knowledge

Estimated share 

of all EvidenceBuilding 

Activities:

 20 %

Major activities: 

 Advisory support research 

 Analyze data filed with FinCEN 

pursuant to the Bank Secrecy Act 

(BSA) to support law enforcement 

and other customers to combat 

money laundering and other forms of 

illicit finance. 

 Perform BSA-related research in 

support of the Treasury 

Department’s review of applications 

submitted to the Committee on 

Foreign Investment in the United 

States (CFIUS). 

 Perform BSA-related research to 

support FinCEN’s role as Financial 

 23 PD FTEs in 

FY 2020 Series 

0301 

 9 SOD FTEs in 

FY2020 Series 

0301 and 

approx. 8 firm, 

fixed-price 

contractors 

 83 ID FTE in 

FY 2020, Series 

0132 

☒ For internal 

policy decisionmaking 

☒ During internal 

strategic 

management 

processes 

☒ By external 

partners 

(government) 

☒ By external 

partners (nongovernment) 
FinCEN - 17 

Type of 

Evidence 

Building 

Activity 

Major Activities and Planned 

Projects

Resource Types Use 

Intelligence Unit of the United 

States. 

 Perform BSA-related research to 

support the FinCEN Exchange 

public-private partnership to enhance 

information sharing. 

 Perform open source and 

commercial database research to 

explore emerging geopolitical issues 

and foreign FIU developments to 

inform decision making related to 

Egmont exchange activity. 



☐ By unaffiliated 

external 

researchers 

☐ Other (describe) 

FY21 and FY22 projects: 

 Issue advisories as necessary or 

appropriate. 

 Develop and host FinCEN 

Exchanges as appropriate. 

 Research and evaluate sensitive 

Egmont exchanges. 

 Create BSA foreign country fact 

sheets to assist with engagement and 

operational activity. 

Analysis 

Routine and 

frequent use of 

data that 

produces insights 

for decision 

making and 

program 

management

Estimated share 

of all EvidenceBuilding 

Activities:

 30 %

Major activities: 

 Performance Measurement 

 BSA data analysis 

 Support law enforcement 

GPRA 

Performance 

Measurement: 

 1 MD FTE, 

Series 0343 

BSA data 

analysis: 

 83 ID FTE in 

FY 2020, Series 

0132 

 2 SOD FTEs in 

FY 2020, series 

0301 and 

approx. 8 firm, 

fixed-price; 76 

other 

contractors 

 6 TD FTE FY 

2020, Series 

2210 

☒ For internal 

policy decisionmaking 

☒ During internal 

strategic 

management 

processes 

☒ By external 

partners 

(government) 

☒ By external 

partners (nongovernment) 

☐ By unaffiliated 

external 

researchers 

☐ Other (describe) 

FY21 and FY22 projects: 

 Increase Intelligence Capacity (FY 

2021) 

 Enhance Systems and Analytical 

Capabilities (FY 2021) 

 Expand Threat and Information 

Sharing (FY 2021) 

 Detect and mitigate money 

laundering vulnerabilities. 

 Support law enforcement 
FinCEN - 18 

Type of 

Evidence 

Building 

Activity 

Major Activities and Planned 

Projects

Resource Types Use 

Statistics 

Collection, 

compilation, and 

processing of 

data for 

describing or 

estimating 

characteristics or 

insights 

concerning 

groups

Estimated share 

of all EvidenceBuilding 

Activities:

 30 %

Major activities: 

 Regulatory impact analyses for 

purposes of the Paperwork 

Reduction Act and to implement 

Executive Order 12866 (1993). 

 Compile data and related analysis in 

connection with publishing the SAR 

Activity Reviews mandated by the 

Anti-Money Laundering Act of 

2020. 

 Compile data and related analysis to 

determine effectiveness, efficiency, 

and potential trends regarding the 

RRP. 

 Compile statistics and create reports 

to support the FinCEN Exchange 

public-private partnership and to 

provide feedback to financial 

institutions and regulators as 

required by the AML Act of 2020. 

 23 PD FTEs in 

FY 2020 Series 

0301 

 9 SOD FTEs in 

FY2020 Series 

0301, 

approximately 8 

firm, fixedprice 

contractors 

 83 ID FTE in 

FY 2020, Series 

0132 

☒ For internal 

policy decisionmaking 

☒ During internal 

strategic 

management 

processes 

☒ By external 

partners 

(government) 

☒ By external 

partners (nongovernment) 

☐ By unaffiliated 

external 

researchers 

☐ Other (describe) 

FY21 and FY22 projects: 

 Regulatory impact analyses for 

purposes of the Paperwork 

Reduction Act and to implement 

Executive Order 12866 (1993). 

These will need to be done when 

FinCEN issues regulations to 

implement the AML Act, and to 

renew OMB control numbers. 

 Compile data and related analysis to 

determine effectiveness and 

efficiency of RRP and to detect

potential BEC or fraud trends.

 Create BSA foreign country fact 

sheets to assist with engagement and 

operational activity. 

 Provide feedback and improve 

coordination with impacted financial 

institutions and regulators, as 

required by the AML Act of 2020. 
FinCEN - 19 

Section III – Additional Information 

A – Summary of Capital Investments 

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

under BSA requirements, which totaled approximately 20 million filings in FY 2020. To 

successfully fulfill its mission, FinCEN relies on secure, advanced IT to manage the collection, 

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

confidence in America’s financial system. On January 1, 2021, Congress passed the National 

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

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

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

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

 

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

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

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

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

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

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

and innovative technical solutions. Beginning in FY2022, FinCEN is increasing its IT portfolio 

by approximately $29M annually to support FinCEN’s current mission architecture and to begin 

development, support, and maintenance for the beneficial ownership requirements of the CTA. 

This increase is required to fully fund FinCEN’s mission IT platform, which is the foundational 

architecture for the CTA beneficial ownership system. To timely and effectively implement these 

new and additional requirements, FinCEN estimates spending $64M in initial development costs 

with estimated obligations of roughly $7M in FY2021, $37M in FY2022, and $20M in FY2023. 

Within those amounts, FinCEN estimates beneficial ownership-specific spending to be $33M in 

the initial development costs with estimated obligations of roughly $4M in FY2021, $23M in 

FY2022, and $6M in FY2023. 

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

investments, can be accessed at: 

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