FinCEN - 1 

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 2008 FY 2009 FY 2010

Enacted Enacted Request $ Change % Change

 BSA Administration and Analysis $76,889 $82,287 $93,444 $11,157 13.6%

 Regulatory Support Programs $8,955 $9,178 $9,316 $138 1.5%

Total Appropriated Resources $85,844 $91,465 $102,760 $11,295 12.3%

Total FTE 321 330 331 1 0.3%

FY 2010 Priorities 

• 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.
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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..................................................................... 3 

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

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

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

2.2 – Operating Levels Table.......................................................................................... 8 

2.3 – Appropriations Detail Table .................................................................................. 9 

2B – Appropriations Language and Explanation of Changes......................................... 9 

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

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

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

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

3.2.2 – Regulatory Support Programs Budget and Performance Plan.......................... 14 

Section 4 – Supporting Materials .................................................................................. 15

4A – Human Capital Strategy Description ................................................................... 15 

4.1 – Summary of IT Resources Table ......................................................................... 18 

4B – Information Technology Strategy ........................................................................ 19 

4.2 – Program Assessment Table.................................................................................. 21 
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 Section 1 – Purpose

1A – Description of Bureau Vision and Priorities 

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

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

Department’s strategic goal of Prevented terrorism and promoted the nation’s security 

through strengthened international financial systems. This role includes ensuring safer 

and more transparent U.S. and international financial systems through the administration 

of the Bank Secrecy Act (BSA). 

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

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

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

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

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

enforcement agencies, both domestically and through exchanges with international 

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

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

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

to collect, analyze, disseminate, and exchange information pursuant to a country’s antimoney laundering/counter-terrorist financing (AML/CFT) legislation and regulations. 

This information includes suspicious or unusual financial activity reported by the 

financial sector. 

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

international partners; and linked to the following strategic goals: 

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

financial supporters, and other perpetrators of financial crime; 

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

illicit activity; and 

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

The total resources required to support FinCEN for FY 2010 are $105,760,000 including 

$102,760,000 for direct appropriation and $3,000,000 from offsetting collections. 

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 international anti-money laundering and counter 

terrorist financing efforts and cooperation; and networking people, entities, ideas, and 

information. 

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

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

BSA regulations to regulated financial institutions, providing guidance regarding 
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regulatory expectations, conducting studies to provide feedback to stakeholders, and 

initiating enforcement actions when appropriate. 

In FY 2008, FinCEN published guidance relating to the anti-money laundering program 

rule for dealers in precious metals, precious stones, or jewels, as well as several pieces of 

guidance to further clarify the definition of money services businesses (MSBs). FinCEN 

also published a notice of proposed rulemaking in the Federal Register that would 

simplify the existing currency transaction reporting exemption regulatory requirements, 

and the bureau continues to work towards presenting a final rule. 

Also in FY 2008, FinCEN published three strategic assessments describing findings from 

Suspicious Activity Report (SAR) analysis to provide feedback to industry, regulatory, 

and law enforcement stakeholders. The assessments identified reporting trends and 

patterns and described vulnerabilities and typologies gleaned from reviewing SAR 

records: after the first year of mandated reporting by certain insurance companies; 

reporting suspected money laundering activities in the residential real estate sector; and 

describing mortgage loan fraud. 

Additionally, in FY 2008, FinCEN worked to publish the draft rule on Chapter 10 and 

redefinition of MSBs. This is an effort to overhaul BSA regulations for inclusion in the 

new Code of Federal Regulations chapter to provide greater clarity in regulations and 

make them easier for industry to follow, as well as more intuitive and responsive to 

industry feedback. 

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 

crimes, FinCEN will: 

• Continue its outreach initiative to the largest fifteen depository institutions in 

the U.S. and expand this to include additional financial service industries; and 

• Continue to support more consistent application of the BSA across industries. 

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

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

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

includes exchange of information with counterpart foreign government FIUs in 107 

countries that are members of the Egmont Group. 

In FY 2008, FinCEN continued to enhance its support to law enforcement agencies by 

focusing on actionable analyses targeted at high-priority money laundering and terrorist 

financing targets. This effort was enhanced through collaborative efforts with Customs 

and Border Protection, the Border Patrol, Immigration and Customs Enforcement, and the 

Coast Guard. Additionally, FinCEN published two comprehensive technical reference 

guides for law enforcement officials (PayPal and MoneyGram). 
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FinCEN continued to work with its Egmont Group partners to develop actionable 

intelligence concerning illicit money flows and provided technical assistance and training 

to Egmont Group candidates and members. FinCEN increased collaboration with the 

Mexican FIU that involved analytical training, multiple on-site visits, support of 

information technology updates, and joint analytical projects. 

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 money 

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

• Improve and expand collaborative relationships with investigative and 

intelligence agencies to exploit SARs for proactive evaluation; and

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

law enforcement.

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 2008, FinCEN began the process to retire magnetic media filing, maximized BSA 

E-Filing capabilities and BSA data validation, and implemented data quality measures to 

improve its management of BSA data and increase coordination and communication with 

its federal stakeholders. The bureau also continued initial planning associated with the 

previously announced multi-year information technology modernization initiative. 

FinCEN implemented a new public website in May 2008 that improved navigation and 

allows customers to more easily find the information needed and created a more flexible 

and sustainable site structure. And finally, in FY 2008, FinCEN increased law 

enforcement access to BSA information through additional MOUs with U.S. Attorney’s 

Offices. 

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: 

• Increase BSA utilization by improving BSA information management and 

analysis; 

• Develop, enhance, or acquire technology to proactively identify, extract and 

analyze specific datasets, entities or subject networks; 

• Upgrade information technology to better retrieve and share BSA information 

with a growing user population; and 

• Continue information technology enhancement. 
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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 2009 Enacted 330 91,465

Changes to Base: 

Maintaining Current Levels (MCLs): - $1,295

Across the Board Program Reduction - (453)

Non-Pay Inflation Adjustment - 495

Pay Annualization - 419

Pay Inflation Adjustment - 834

Subtotal FY 2010 Changes to Base - $1,295

Total FY 2010 Base 330 92,760

Program Changes: 

Program Increases: 1 $10,000

Implement Information Technology Modernization 1 10,000

Subtotal FY 2010 Program Changes 1 $10,000

Total FY 2010 President's Budget Request 331 102,760

2A – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ...........................................+$1,295,000 / +0 FTE 

Across the Board Program Reduction -$453,000 / +0 FTE 

FinCEN continues to focus on improving the efficiency of its operations through a 

disciplined process of productivity improvement. 

Non-Pay Inflation Adjustment +$495,000 / +0 FTE 

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

supplies, equipment and GSA rent. 

Pay Annualization +$419,000 / +0 FTE 

Funds are requested for the FY 2010 cost of the January 2009 pay raise. 

Pay Inflation Adjustment +$834,000 / +0 FTE 

Funds are requested for the January 2010 pay raise. 

Program Increases .......................................................................+$10,000,000 / +1 FTE 

Implement Information Technology Modernization +$10,000,000 / +1 FTE 

This request supports initial FinCEN efforts to modernize the BSA technical 

environment. FinCEN is working on prioritizing multiple efforts within the overall 

modernization initiative, and considering potential modular approaches to improving 

BSA data and analysis capabilities. In FY 2007, FinCEN developed a strategy to 

modernize the BSA data architecture to better serve its internal and more than 10,000 

external users that rely on accurate, timely, and reliable BSA data to identify money 

laundering, terrorist financing, tax evasion, and vulnerabilities in the financial industry. 

The modernization will reengineer the BSA data architecture, update antiquated 

infrastructure required to support data capture and dissemination, implement innovative 

web-services and enhanced electronic-filing, and provide analytical tools. This 
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investment will begin to enrich and standardize BSA data to maximize value, evaluate 

and deploy advanced analytical technologies, and establish more effective security 

technologies to enhance data confidentiality and integrity within FinCEN’s environment. 

FinCEN’s current technology environment has not kept pace with today’s USA 

PATRIOT Act requirements. The number of institutions falling under the purview of the 

BSA has grown exponentially in the last six years and FinCEN anticipates continued 

robust growth in the future. The current technology environment is ill-equipped to meet 

21st century realities and unable to quickly adapt to changing financial indicators and 

patterns of illicit activity. This funding request is a crucial component for promoting cost 

efficiency across several sectors of the USG and for meeting the needs of a modernized 

financial services industry. 
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2.2 – Operating Levels Table 

Bureau: Financial Crimes 

Enforcement Network

FY 2008 

Enacted

FY 2009 

President's 

Budget

Congressio

nal Action

Including 

Rescission

FY 2009 

Enacted 

Level

Proposed 

Reprogram

mings

FY 2009 

Proposed 

Operating 

Level

FY 2010 

Requested 

Level

% Change

FY 2009 

to FY 2010

 

FTE 321 343 0 330 0 330 331 0.30%

Object Classification: 

11.1 - Full-time permanent 31,531 33,092 0 33,092 0 33,092 34,453 4.11%

11.3 - Other than full-time permanent 284 284 0 284 0 284 294 3.52%

11.5 - Other personnel compensation 526 526 0 526 0 526 545 3.61%

12 - Personnel benefits 8,433 9,030 0 9,030 0 0 9,075 0.00%

13 - Benefits for former personnel 0 0 0 0 0 9,030 0 -100.00%

21 - Travel and transportation of 

persons 

1,190 1,216 0 1,216 0 1,216 1,153 -5.18%

23.1 - Rental payments to GSA 5,117 5,343 0 5,343 0 5,343 5,380 0.69%

23.2 - Rental payments to others 1,328 1,434 0 70 0 70 71 1.43%

23.3 - Comm, utilities, and misc 

charges 

0 0 0 1,364 0 1,364 1,399 2.57%

24 - Printing and reproduction 400 450 0 450 0 450 454 0.89%

25.1 - Advisory and assistance 

services 

1,815 1,815 0 1,815 0 1,815 1,830 0.83%

25.2 - Other services 11,758 13,136 0 13,266 0 13,266 13,178 -0.66%

25.3 - Other purchases of goods and 

services from Govt. accounts 

12,706 14,198 0 14,198 0 14,198 14,445 1.74%

25.4 - Operation and maintenance of 

facilities 

960 960 0 960 0 960 968 0.83%

25.6 - Medical care 145 153 0 153 0 153 155 1.31%

25.7 - Operation and maintenance of 

equip 

4,815 5,003 0 5,003 0 5,003 5,056 1.06%

26 - Supplies and materials 409 444 0 444 0 444 449 1.13%

31 - Equipment 4,427 4,251 0 4,251 0 4,251 13,855 225.92%

Total Budget Authority $85,844 $91,335 $0 $91,465 $0 $91,465 $102,760 12.35%

 

Budget Activities: 

BSA Administration and Analysis 76,889 82,157 0 82,287 0 82,287 93,444 13.56%

Regulatory Support Programs 8,955 9,178 0 9,178 0 9,178 9,316 1.50%

Total Budget Authority $85,844 $91,335 $0 $91,465 $0 $91,465 $102,760 12.35%

 
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2.3 – Appropriations Detail Table 

Dollars in Thousands 

FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

New Appropriated Resources:

BSA Administration and Analysis 303 $68,606 321 $76,889 329 $82,287 330 $93,444 0.30% 13.56%

Regulatory Support Programs 8,942 8,955 9,178 9,316 1.50%

Subtotal New Appropriated Resources 303 $77,547 321 $85,844 329 $91,465 330 $102,760 0.30% 12.35%

Other Resources:

Recoveries 741 741 407 407 0.00%

Offsetting Collections - Reimbursable 4,310 5,251 1 6,000 1 3,000 -50.00%

Available multi-year/no-year funds 7,152 7,343 14,300 14,000 -2.10%

Transfers In/Out 221 225 225 225 0.00%

Subtotal Other Resources 0 $12,424 0 $13,560 1 $20,932 1 $17,632 0.00% -15.77%

Total Resources Available for Obligation 303 $89,971 321 $99,404 330 $112,397 331 $120,392 0.30% 7.11%

Baseline to FY 2010

FY 2008 FY 2008 FY 2009 FY 2010 FY 2009

Resources Available for Obligation Obligations Enacted Enacted

% Change

2B – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes

DEPARTMENT OF THE TREASURY 

FINANCIAL CRIMES ENFORCEMENT NETWORK 

Federal Funds 

SALARIES AND EXPENSES: 

For necessary expenses of the Financial Crimes 

Enforcement Network, including hire of passenger motor 

vehicles; travel and training expenses of non-Federal and 

foreign government personnel to attend meetings including 

for course development 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, [$91,465,000] 

$102,760,000 of which not to exceed [$16,340,000] 

$26,085,000 shall remain available until September 30, 

[2011] 2012; and of which [$9,178,000] $9,316,000 shall 

remain available until September 30, [2010] 2011: 

Provided, That funds appropriated in this account may be 

used to procure personal services contracts. 

The new language would 

specifically allow 

FinCEN to fund travel 

and training expenses of 

non-Federal and foreign 

government personnel to 

obtain the necessary 

expertise required to 

develop and prepare 

training materials to meet 

its mission. This 

language will specifically 

allow FinCEN to gather 

course development 

resources from state and 

local organizations, 

public and private, nonprofit institutions, public 

and private business, and 

foreign government 

personnel.
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2C – Legislative Proposals 

FinCEN does not have any legislative proposals for FY 2010. 
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Section 3 – Budget and Performance Plan

This table lists all FY 2010 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 2009 

Enacted

FY 2010 

Request Percent Change

 U.S. & intl financial sys 97,465 105,760 8.51%

Total $97,465 $105,760 8.51%

3A – BSA Administration and Analysis ($93,444,000 from direct appropriations and 

$3,000,000 from reimbursable programs): This activity comprises FinCEN’s efforts to 

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

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

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

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

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

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

combating financial crime by facilitating the exchange of investigative information; 

identifying foreign and domestic money laundering and terrorist financing trends, 

patterns, and techniques; and liaison with and support of intelligence initiatives within the 

intelligence community and within Treasury. This activity also incorporates efforts to 

support large-scale, complex law enforcement investigations involving terrorist 

financing, money laundering, and other financial crimes. 

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

institutions for BSA compliance to ensure consistency across regulated industries. 

Through these efforts and direct outreach, FinCEN also assists regulated financial 

institutions in establishing risk-based anti-money laundering programs with appropriate 

policies, procedures, and internal controls and maintaining 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 
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international anti-money laundering/counter-terrorist financing regulatory standards and 

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

laundering/counter-terrorist financing missions. 

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

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

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

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

includes development of threat assessments, industry reports, and technical guides 

describing financial transaction mechanisms. Additionally, FinCEN identifies 

individuals and networks involved in suspicious financial activity, referring that 

information to appropriate law enforcement agencies. 

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

accessibility, dissemination, and use of the highly sensitive confidential information 

collected under the Act. FinCEN provides direct access to BSA information to 

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

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

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

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

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

BSA analytical tools used by FinCEN analysts. 

Other Resources: Offsetting collections and reimbursements totaling $3,000,000 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. 

3.2.1 – BSA Administration and Analysis Budget and Performance Plan 

BSA Administration and Analysis Budget Activity

FY 2006 FY 2007 FY 2008 FY 2009 FY 2010

Resource Level Obligated Obligated Obligated Enacted Request

 Appropriated Resources $64,458 $64,780 $68,606 $82,287 $93,444

 Reimbursable Resources $4,473 $0 $4,310 $6,000 $3,000

Total Resources $68,931 $64,780 $72,916 $88,287 $96,444

Budget Activity Total $68,931 $64,780 $72,916 $88,287 $96,444

FY 2006 FY 2007 FY 2008 FY 2009 FY 2010 Budget Activity Performance Measure Actual Actual Actual Target Target

BSA Administration 

and Analysis 

Percent of federal and state regulatory 

agencies with memoranda of 

understanding/information sharing agreements 

(%) (Ot) 

0 0 41 45 51

BSA Administration 

and Analysis 

Percent of FinCEN's compliance MOU 

holders finding FinCEN's information 

exchange valuable to improve the BSA 

consistency and compliance of the financial 

system (%) (Oe) 

0 0 64 66 68

BSA Administration 

and Analysis 

Percentage of bank examinations conducted 

by the Federal Banking Agencies indicating a 

8 5.2 2.5 5.2 5.2
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systemic failure of the anti-money laundering 

program rule (%) (Oe) 

BSA Administration 

and Analysis 

Percentage of customers satisfied with the 

BSA E-Filing (%) (Ot) 

92 94 93 90 90

BSA Administration 

and Analysis 

Percentage of FinCEN's Regulatory Resource 

Center customers rating the guidance received 

as understandable (%) (Ot) 

94 91 94 90 90 

BSA Administration 

and Analysis 

The percentage of domestic law enforcement 

and foreign financial intelligence units finding 

FinCEN's analytical reports highly valuable 

(%) (Oe) 

77 82 83 80 80 

BSA Administration 

and Analysis 

Average time to process enforcement matters 

(in years) (E) 

1 1.1 0.7 1 1 

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

In the regulatory area, FinCEN’s goal to provide financial institutions with 

understandable guidance is critical to institutions establishing anti-money laundering 

programs that comply appropriately with the BSA. FinCEN’s goal was to maintain a 90 

percent satisfaction level and it surpassed the target with 94 percent of 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 through imposition of civil money penalties when appropriate. Timely 

enforcement action is essential to deter non-compliance with the BSA. In FY 2008, 

FinCEN surpassed its target of an average time to process enforcement matters of 1.0 

years with an average time of 0.7 years. 

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

partners by providing analyses of BSA information, and measures the percentage of 

customers finding FinCEN’s analytical 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 2008, FinCEN surpassed its 

target of 79 percent with 83 percent of its customers finding the analytic products highly 

valuable. 

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

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

satisfaction level and to identify where improvements are needed. The FY 2008 target 

was to maintain at least a 90 percent satisfaction level, and FinCEN surpassed its target 

with 93 percent. 

3B – Regulatory Support Programs ($9,316,000 from direct appropriations): This 

activity supports implementation, strengthening and clarification of the programmatic 

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

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

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

especially related to the money services business (MSB) industry to ensure compliance, 
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respond to public inquiries, distribute forms and publications, and support collection and 

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

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

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

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

institutions, especially related to the MSB industry. 

3.2.2 – Regulatory Support Programs Budget and Performance Plan 

Regulatory Support Programs Budget Activity

FY 2006 FY 2007 FY 2008 FY 2009 FY 2010

Resource Level Obligated Obligated Obligated Enacted Request

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

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

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

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

FinCEN achieved the following quantifiable results in FY 2008: 

• Increased the number of registered MSBs to 38,594 as of October 11, 2008. FinCEN 

plans to maintain or exceed this level by FY 2010; 

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

MSBs, coordinating with law enforcement and state regulatory agencies on 

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

registration by publishing guidance and participating in industry outreach events. 

From September 2002 through August 2008, 5,423 individuals/entities suspected of 

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

SARs filed by depository institutions; and 

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

MSBs. 

 

For detailed information about each performance measure, including definition, 

verification and validation, please go to: 

http://www.treasury.gov/offices/management/dcfo/accountability-reports/
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Section 4 – Supporting Materials 

4A – Human Capital Strategy Description 

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

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

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

improve accountability. 

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

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

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

service. 

In terms of competitive sourcing, FinCEN submitted its FY 2008 FAIR Act Inventory to 

the Department in April 2008, and continues to rely upon the private sector to perform 

commercial activities, especially in the information technology environment. 

FinCEN recently completed several organizational realignments throughout the bureau to 

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

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

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

Additionally, the information technology division is establishing a customer service 

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

customers. 

FinCEN leaders and managers effectively manage people and sustain a learning 

environment that drives continuous improvement in performance. In FY 2008, FinCEN 

continued to strengthen the skills of its current leaders and promote leadership skills at all 

levels. Mandatory training for all supervisors/managers included a two day class on 

Making the Most of Performance Appraisals in October 2007, and two days on Essential 

Supervisory Skills in May and August 2008, which covered EEO and employee discipline 

topics. Nine webinars on a wide range of leadership topics were also offered, and six 

employees participated in government sponsored leadership development programs. 

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

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

emphasizing leadership development activities at all levels. The Leadership 

Development Program Directive, formalized in August 2008, defines essential training 

for new managers and continuing education requirements for all managers. The directive 

promotes growth, commitment, and empowerment for executives, managers and 

supervisors through: the use of assessment tools, required new supervisor/manager 

training, leadership training and continuing education. 
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In order to demonstrate a results-oriented, high performing workforce, FinCEN uses a 

five-tier performance management system. The performance system requires that each 

employee be placed on performance standards that include three individual commitments 

linked directly to the strategic plan. This performance system allows managers to 

differentiate performance levels among employees and hold employees accountable for 

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

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

development. 

FinCEN also has a complementary Awards and Recognition Program, which includes an 

annual Director’s Awards and Recognition Program. In FY 2007, 78 percent of the 

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

while 1.4 percent was rated below fully successful and appropriate remedial actions were 

taken. 

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

efforts are listed below: 

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

• Maintained a Diversity Advisory Committee; 

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

in all supervisory performance plans to address EEO principles, workplace 

conflict, supporting EEO plans and diversity hiring requirements; 

• Conducted a Diversity Day Training Conference for all employees; 

• Provided mandatory EEO training to all Managers and Supervisors; 

• Partnered with diverse academic groups to attract student interns of diverse 

backgrounds; and 

• Established contacts with special interest groups to attract applicants from diverse 

populations. 

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

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

employees. In FY 2008, FinCEN conducted a skills gap assessment for its mission 

critical Regulatory Specialists and Law Enforcement Liaison Specialists. Using the 

results of those skills gap assessment, training development plans were created for those 

mission critical occupations along with its mission critical Intelligence Research 

Specialist. A comprehensive BSA Training Program was deployed and in-house training 

focused on high level analytic training to close skills gaps. In January 2008, a Rotational 

Assignment Program was created. It provides temporary rotational assignments within 

and outside of the bureau to its highly qualified and highly motivated employees who 

wish to make a significant contribution to the bureau and to further their own learning 

and career development. Since January 2008, seven FinCEN offices made rotational 

opportunities available in their offices. Eight employees were selected for those 

rotations. Two external organizations, the Office of Foreign Assets Control and the 

Customs and Border Protection’s National Targeting Center-Cargo each offered to host a 

FinCEN employee as a rotational opportunity. 
FinCEN - 17 

In May 2008, FinCEN deployed the Treasury-wide Treasury Learning Management 

System (TLMS) to enable employees to manage their own learning, and supervisors to 

electronically manage subordinates’ learning requests and progress. Employees now 

access training opportunities, on-line courses, external training requests, and their own 

training histories 24 hours a day, seven days a week. FinCEN can efficiently disseminate 

bureau-wide announcements of training and professional development linked to 

necessary actions, mandatory training, and OPM-required data. Full access to unabridged 

contents of 20,000 books on business and technical topics are available in a searchable, 

collaborative environment through the TLMS. 

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

the last year. For example, in FY 2008, ten students were hired under the Student 

Temporary Employment Program (STEP); 4 in FY 2007, and 16 in FY 2006. FinCEN 

utilized the Veterans Employment Opportunity Act (VEOA) and the Veteran 

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

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

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

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

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

76 percent feel that they are held accountable for achieving results. According to the 

bureau’s performance assessment results, FinCEN continues to clearly show distinctions 

of and consequences in levels of performance. FinCEN continues to follow up on some 

issues from the last Federal Human Capital Survey to identify ways to increase scores by 

improving employee satisfaction. FinCEN continues to review the performance 

management system to identify areas for improvement. 
FinCEN - 18 

4.1 – Summary of IT Resources Table Dollars in Thousands 

Information Technology Investments

FY 2006 FY 2007 FY 2008 

Major IT Investments / Funding Source Budget Activity Enacted Enacted Enacted BSA Information Technology Modernization Cross Border Major 

Major IT Investments BSA Administration and Analysis 0.0 0.0 0

Non-Major IT Investments BSA Administration and Analysis 10.4 11.4 17

Infrastructure Investments BSA Administration and Analysis 8.3 8.5 9

Enterprise Architecture BSA Administration and Analysis 0.1 0.2 0

Total IT Investments BSA Administration and Analysis 18.8 20.1 27
FinCEN - 19 

4B – Information Technology Strategy 

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

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

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

FinCEN continues to face a critical need to improve the quality and accessibility of its 

data and increase responsiveness to stakeholders by introducing flexible and innovative 

technical solutions. 

National and global law enforcement agencies depend on accurate, timely, and reliable 

financial information from FinCEN to track money trails, identify money laundering, and 

unravel terrorist financing networks. 

In 2007, the number of BSA reports filed was slightly over 18 million, with 

approximately 1.3 million SARs for all covered industries. FinCEN recognizes the 

enormous obligation on one of its critical stakeholders—regulated financial institutions. 

Feedback from financial institutions, obtained through a 2007 survey on E-filing, 

indicated that FinCEN needs to streamline how it captures information through the 

various forms and simplify means to submit information. 

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

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

stakeholders, FinCEN began documenting an information technology modernization 

vision and strategy (IT MV&S) in FY 2007, resulting in an Enterprise Transition Strategy 

(ETS). This strategy spans all of the bureau’s lines of business and serves as the 

organization’s roadmap for aligning its IT portfolio with its business objectives and 

processes. 

As a result of the IT MV&S effort, FinCEN has developed a multi-year strategic vision, 

which focuses on two keys aspects—information management and analysis and 

stakeholder relations and collaboration. By establishing an enterprise-wide information 

management and analysis framework, FinCEN will be equipped with better decisionmaking ability and control of BSA data collection and processing, as well as improved 

data quality and integrity. 

In FY 2008, FinCEN and IRS continued to forge their partnership towards a modernized 

environment. In mid 2008, the Modernization Executive Group (MEG) was created and 

currently serves as the highest level, integrated governing body in support of BSA 

information management and is tri-chaired by the Treasury Chief Information Officer, the 

IRS Deputy Commissioner, and the FinCEN Director. Once established, the MEG 

chartered the Executive Steering Committee (ESC) , made up of seven voting members 

from IRS, FinCEN, and the Departmental Office, to ensure BSA modernization 

objectives are met, risks are managed appropriately, and expenditure of enterprise 

resources is fiscally sound. The MEG also requested an independent assessment of the 

current system of record for BSA data be performed to determine if portions could be 

reused in the modernized environment. The assessment concluded that the current 

system of record, WebCBRS, could not be used to support the capabilities identified in 
FinCEN - 20 

the modernized BSA environment. Those results were presented to and agreed upon by 

the MEG, and as a result, IRS and FinCEN are partnering to develop new strategies to 

deliver all of the critical components required to meet the needs of BSA stakeholders. 

Lastly, FinCEN’s BSA IT Modernization program supports the Treasury FY 2007-2012 

Strategic Plan’s national security strategic goal, enables FinCEN to meet their statutory 

requirements, closes the known gaps and provides more efficient filing for industry, 

reduces costs to industry and Government, and makes information more accessible and 

useful to about 300 external agencies at the Federal and State level. 
FinCEN - 21 

4.2 – Program Assessment Table 

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

Year Evaluated: 2005 

Rating: Moderately Effective 

OMB Major Findings/Recommendations 

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

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

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

However, some activities are managed by another entity and are outside the scope of 

the performance measures. 

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

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

of users directly accessing data, and the share of filings submitted electronically. 

Bureau Actions Planned or Underway 

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

including streamlining reporting obligations and increasing feedback and notices to 

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

In Q4 FY 2008 SAR Acknowledgement feature was communicated to the Data 

Management Council. The SAR Acknowledgment concept of operations and highlevel requirements document were completed by September 2008. Due to system 

constraints with WebCBRS, this feature will not be implemented until late FY 2009. 

Implement Adobe Forms for E-Filing in Q3 FY 2009. 

2. 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 2008 the 

WebCBRS Release to correct selected high-priority data quality issues covered 19 

items and 456 closed items. There were 387 items of which 8 were urgent. In FY 

2009 implement two WebCBRS releases to correct selected high priority data quality 

issues. Report on number of closed data quality issues in Q4 FY 2009.
FinCEN - 22 

3. 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 Q4 FY 2008 the stakeholder forum 

strategy was in progress. Due to resource constraints, a forum will not occur until FY 

2009. Provide SAR Acknowledgement E-Filing requirements to ECC-Detroit and 

finalize implementation plan in Q1 FY 2009. Implement Adobe Forms for E-Filing 

in Q3 FY 2009. 
FinCEN - 23 

Evaluation Name: Bank Secrecy Act (BSA) Analysis 

Year Evaluated: FY 2006 

Rating: Adequate 

OMB Major Findings/Recommendations 

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

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

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

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

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

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

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

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

that it produces, but significant effort will be required to achieve its long-term target 

of 75 percent in FY 2008. FinCEN has increased the percentage of advanced analytic 

products from 1.6 percent in FY 2004 to 39 percent in FY 2006. 

Bureau Actions Planned or Underway 

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

products. The feasibility study was completed in FY 2008. A decision was made to 

focus efforts on a development and implementation of a more collaborative process 

for intake, evaluation, and prioritization of customer requests that will enhance 

FinCEN's understanding of customer needs and customer's understanding of products 

and services. A new action plan has been developed for this effort. These actions 

complete FinCEN’s response to this recommendation. 

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

financing and anti-money laundering programs worldwide. A survey was 

administered to technical assistance customers during Q3 and Q4 of FY 2008. These 

same impact questions were incorporated into the Foreign Investigative Case Report 

survey to provide a more comprehensive measure of FinCEN's impact on 

international AML/CFT efforts. Based on the results, FinCEN established a baseline 

and set future targets considering both the results of technical assistance and case 

support. These actions, and the establishment of a measure, complete FinCEN's 

response to this recommendation. 

3. 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 discuss/solicit feedback on the proposal. In FY 2009, upon 
FinCEN - 24 

completion of the comment period, the concept of operations plan will be updated and 

implementation will begin. 
FinCEN - 25 

Evaluation Name: Bank Secrecy Act (BSA) Administration 

Year Evaluated: 2006 

Rating: Results Not Demonstrated 

OMB Major Findings/Recommendations 

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

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

of the reporting requirements. 

• Although FinCEN has made progress in executing memoranda of understanding 

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

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

industries, particularly the money services business industry. 

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

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

needed to measure the impact of program activities on preventing the misuse of the 

financial system by those engaged in illicit activities. 

Bureau Actions Planned or Underway 

1. Developing measures of the impact of program activities on preventing the misuse of 

the financial system by those engaged in illicit activities. A survey was developed 

and conducted in FY 2008 and baseline performance was established. To further 

enhance performance measures, FinCEN refined their measure monitoring the 

number of federal and state regulatory agencies with information sharing agreements 

reflecting progress toward FinCEN's target of 130. These actions, and the previous 

establishment of measures, complete FinCEN's response to this recommendation. 

2. FinCEN will meet with staff from the Office of Information and Regulatory Policy 

(OIRA) to discuss the tools and methods they employ when making cost/benefit 

decisions related to regulations. FinCEN met with OIRA in the third quarter of FY 

2008 to discuss regulatory impact analysis. These actions complete FinCEN’s 

response to this recommendation. 

3. 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 will facilitate the clearance process for a 

Notice of Proposed Rulemaking (NPRM) and an Advanced Notice of Proposed 

Rulemaking (ANPRM) to revise the money services business rules. 

4. 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 
FinCEN - 26 

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 has 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. 

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

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