Department of the Treasury

Financial Crimes Enforcement 

Network

Congressional Budget 

Justification and Annual 

Performance Report and Plan

FY 2020
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 .............................................................................................. 4

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

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

1.3 – Operating Levels Table...................................................................................................... 8

D – Appropriations Language and Explanation of Changes ...................................................... 9

E – Legislative Proposals............................................................................................................ 9

Section II – Annual Performance Plan and Report................................................................. 10

A – Strategic Alignment ........................................................................................................... 10

B – Budget and Performance by Budget Activity .................................................................... 11

2.1.1 – BSA Administration and Analysis Resources and Measures....................................... 11

BSA Administration and Analysis Budget and Performance................................................... 12

C – Changes in Performance Measures.................................................................................... 13

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

A – Summary of Capital Investments....................................................................................... 14
FinCEN - 3

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 

Summary of the Request: The FY 2020 President’s Budget requests additional resources totaling 

$9,697,000—providing $7,411,000 for three critical program areas and $3,318,000 for two 

program areas previously included in the FY 2019 President’s Budget; and program decreases 

totaling $2,226,000. Specifically, FinCEN will enhance its national security capacity, which 

includes expanding its efforts to combat cybercrime threats; expanding Special Measures 

enforcement efforts; maintaining cyber security investments; sustaining contractor support 

related to national security intelligence analysis; and beginning the development of a non-bank 

financial institutions profile that targets compliance toward high risk institutions. 

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

the Under Secretary for Terrorism and Financial Intelligence (TFI). FinCEN supports the 

Treasury Strategic Goal 3: Enhance National Security and Goal 5: Achieve Operational 

Excellence. In Strategic Goal 3, FinCEN supports the following Treasury Strategic Objectives: 

3.1 Strategic Threat Disruption – Identify, disrupt, and dismantle priority threats to the U.S. and 

international financial system and Treasury Strategic Objective 3.2 Anti-Money 

Laundering/Combating Financing of Terrorism (AML/CFT) Framework – Identify and reduce 

vulnerabilities in the U.S. and international financial system to prevent abuse by illicit actors.

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

• Developing and issuing regulations under the Bank Secrecy Act (BSA); 

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

regulatory partners; 

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

information sharing with FIUs in 158 partner countries; 

• Receiving millions of new financial reports each year; 

• Securing and maintaining a database of over 190 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.
FinCEN - 4

1.1 – Appropriations Detail Table

Dollars in Thousands

Financial Crimes Enforcement Network 

Appropriated Resources

New Appropriated Resources FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT

BSA Administration and Analysis 280 $115,003 332 $115,003 359 $124,700 27 $9,697 8.13% 8.43%

Subtotal New Appropriated Resources 280 $115,003 332 $115,003 359 $124,700 27 $9,697 8.13% 8.43%

Other Resources

 Reimbursables 1 $3,000 1 $3,000 1 $3,000 0 $0 0.00% 0.00%

 Recovery from Prior Years 0 $500 0 $500 0 $500 0 $0 0.00% 0.00%

Subtotal Other Resources 1 $3,500 1 $3,500 1 $3,500 0 $0 0.00% 0.00%

Total Budgetary Resources 281 $118,503 333 $118,503 360 $128,200 27 $9,697 8.11% 8.18%

* FY 2018 shows actual FTE usage. This column reflects levels appropriated in P.L. 115-141 Consolidated Appropriations Act, 2018. 

For further details on the execution of these resources see the 2020 Budget Appendix chapter for the Department of the Treasury.

FY 2018 * FY 2019 FY 2019 to FY 2020

Enacted Annualized CR Request Change % Change

FY 2020

1.2 – Budget Adjustments Table

Financial Crimes Enforcement Network (FinCEN) FTE

FY 2019 Continuing Resolution 332 $115,003

Changes to Base:

Maintaining Current Levels (MCLs): 0 $1,194

Non-Pay 0 $1,194

Subtotal Changes to Base 0 $1,194

Total FY 2020 Base 332 $116,197

Program Changes:

Program Decreases 0 ($2,226)

Programmatic Contract and Equipment Reductions 0 ($2,226)

Program Increases: 27 $10,729

Enhance National Security Capacity 0 $2,118

Develop NBFI Risk Assessment Model 0 $1,200

Operations and Maintenance (O&M) of Prior-year 

Enterprise-wide Cybersecurity investments 0 $511

Expand Efforts to Combat Cybercrime Threats 13 $3,563

Expansion of Special Measures Enforcement Efforts 14 $3,337

Subtotal Program Changes 27 $8,503

Total FY 2020 Request 359 $124,700

Dollars in Thousands

C – Budget Increases and Decreases Description

Maintaining Current Levels (MCLs)........................................................+$1,194,000 / +0 FTE

Non-Pay +$1,194,000 / +0 FTE 

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

equipment.
FinCEN - 5

Program Decreases. ......................................................................................-$2,226,000 / -0 FTE

Programmatic Contract and Equipment Reductions -$2,226,000 / -0 FTE

This reduction will be taken through evaluation of increases or changes in proposed acquisitions 

of contractual services and equipment. FinCEN will evaluate contracts during the renewal 

process to absorb this reduction.

Program Increases. .................................................................................+$10,729,000 / +27 FTE

Enhance National Security Capacity +$2,118,000 / +0 FTE

These funds were also included in the FY 2019 President’s Budget and are necessary to sustain 

FinCEN’s increased contractor resources needed to adequately support Treasury’s Terrorism and 

Financial Intelligence priorities. FinCEN is increasingly called upon to identify sources of 

revenue for illicit actors and their attempts to access and exploit the international financial 

system. These requests stem from the growing threats from rogue nations including the 

Democratic People’s Republic of North Korea (DPRK) and continued efforts to combat 

international organized crime, terrorism, narcotics, and proliferation. These additional funds will 

support these activities, as well as the growing analysis of and demand for FinCEN’s BSA data 

to assist in combating the emerging threats to the financial system.

Develop NBFI Risk Assessment Model +$1,200,000 / +0 FTE

These funds were also included in the FY 2019 President’s Budget and will allow FinCEN to 

begin the development of a Non-Bank Financial Institution (NBFI) Risk Assessment Model that 

will ultimately improve FinCEN’s ability to identify, detect, and examine the highest risk NBFIs 

and foster enhanced BSA compliance within the NBFI sectors. 

NBFIs encompass approximately 320,000 financial institutions – including money services 

businesses (MSBs), including virtual currency exchanges and administrators; casinos and card 

clubs; dealers in precious metals, stones, or jewels; certain insurance companies; and non-bank 

mortgage lenders and originators – and over $13 trillion in financial services. NBFIs have the 

potential to create significant vulnerabilities for the financial system that can be exploited by 

money launders, terrorist financiers, and other criminal actors. They also present inherent risks 

to the U.S. and global financial system ranging from the lack of traditional depository institution 

relationships for MSBs; the abuse of casinos and card clubs by criminal organizations; the 

relative isolation of precious metals, stones, and jewels from the financial services sector; and the 

rapidly changing technologies and customer identification challenges of virtual currency 

exchanges and administrators. 

This effort is the first step to ensure that these sectors are effectively supervised; and, it is a key 

Treasury Department priority not only to mitigate these vulnerabilities but also to protect the 

financial system from criminal abuse. This initiative will also help NBFIs continue to play their 

important role in financial inclusion and the economy, and to improve the government’s 

oversight and supervision of this industry.
FinCEN - 6

Operations and Maintenance (O&M) of Prior-year Enterprise-wide Cybersecurity Investments 

+$511,000/ +0 FTE

This funding will support O&M for prior year Cybersecurity Enhancement Account investments. 

O&M will be funded by Treasury Bureaus through Treasury Franchise Fund billing. This 

increase represents FinCEN’s portion of the $17,500,000 million O&M total.

Expand Efforts to Combat Cybercrime and Cryptocurrency Threats +$3,563,000/+13 FTE 

This funding will allow FinCEN to expand efforts to combat cyber threats to financial 

institutions, cybercrime, and exploitation of emerging payment systems such as cryptocurrency. 

These efforts follow the money trail of virtual currencies and related financial instruments to 

identify the malicious cyber actors or networks receiving payment for conducting illicit financial 

activities or executing online scams. Through the BSA, financial institutions currently report to 

FinCEN suspicious cyber activity; this information is especially important because in many cases 

cyber actors have tested their tools on banks before deploying them elsewhere. To understand 

and utilize this information, FinCEN has developed unique expertise in cybercrime and 

cryptocurrency that is essential to understanding the evolving nature of financial crimes and their 

complex financial trails. 

FinCEN’s unique skillset related to cybercrime and cryptocurrency threats is in high demand 

with other government agencies. In the past, resource constraints have severely limited 

FinCEN’s ability to share its unique knowledge in this niche area.

These resources will ensure the expansion of its research and analytical services on the growing 

volume of BSA data related to cyber threats received from financial institutions. This includes 

additional leads provided by the new Suspicious Activity Report (SAR) form released in July 

2018, which encourages additional reporting of cyber threat information, including indicators 

such as malware signatures, malicious domains, and command and control infrastructure. These 

additional resources are critical to ensuring that Treasury, law enforcement, and the broader U.S. 

government can take full advantage of the additional SAR detail regarding cyber threats that 

affect U.S. financial institutions and their customers. In addition, this request also includes 

staffing to enhance FinCEN’s BSA enforcement responsibilities as the sole U.S. regulator for 

virtual currency, and support for international efforts to coordinate financial fraud recovery 

related to business e-mail compromise cyber threats (referred to as “rapid response”). 

These additional resources to expand efforts to combat cybercrime and crytocrurrency threats 

will allow FinCEN to meet the expected growing demand for its products and services (e.g., an 

expected 78 percent increase in cyber cases, enforcement actions, and reports, including a 94 

percent expected increase in the number of strategic products disseminated; and a 150 percent 

expected increase in the number of cyber-related enforcement actions). The additional resources 

will also provide FinCEN the ability to increase the stolen assets recovered by the rapid response 

cases by 150 percent (from an anticipated $60M in FY 2019 to a projected $150M in FY 2022). 

Expansion of Special Measures Enforcement Efforts +$3,337,000/+14 FTE

These funds will allow FinCEN to meet the growing Special Measures workload. These 

activities focus on investigating foreign money laundering and terrorist financing threats to the 

U.S. financial system and taking administrative actions to prevent bad actors from accessing it. 
FinCEN - 7

Over the past several years, data collected through FinCEN’s Special Measures tools and 

authorities has become one of the key sources of enforcement actions against ongoing money 

laundering concerns including rogue nation states, terrorists, and other national security threats. 

FinCEN is in a unique position to utilize the vast amount of information from special collection 

authorities to identify previously unknown money laundering concerns with the unique data 

collected under its authorities. Special Measures authorities are a very effective process to 

identify bad actors within the financial system, but they require a significant infusion of human 

capital as this process is lengthy and involves extensive legal coordination. In addition, working 

with foreign partners to address these threats can have a powerful multiplier effect. For example, 

recent Section 311 actions against Bank of Dandong (China) demonstrate the major impacts that 

these actions have on reducing specific vulnerabilities in the U.S. and international financial 

system. 

This funding will allow FinCEN to expand its use of its unique authorities such as Section 311, 

the Foreign Financial Agency rule, Demand Letters, and Geographic Targeting Orders—all of 

which were previously underutilized prior to FY 2017—to increase enforcement and data 

collection efforts. With data collected under these authorities continuously increasing, there is a 

potential to receive millions of transaction records from a single series of requests. For example,

transactions obtained from Demand Letters increased from 2.6 million to 40.5 million between 

2016 and 2018. This data is being used to identify enforcement and investigative leads as well as 

strategic trends and patterns. These special collection authorities are providing data previously 

unavailable, but in order to continue this critical focus, the function needs to grow to a level 

sufficient to meet the demand. Additional funds will allow FinCEN to maximize the use of these 

authorities to combat current and future national security threats, including global money 

launderers and proliferators. 

In short, FinCEN’s Special Measures authorities have become one of the key sources of 

information used to disrupt the illicit use of the financial system and obtain special collection 

information directly from financial institutions. These resources are essential to address the 

national security threats such as DPRK, Iran, Hezbollah, Venezuela, cybercrime, fraud, and 

transnational organized crime. FinCEN anticipates an increase of 30 percent in the number of 

completed 311 actions and Geographic Targeting Order actions by FY 2022. FinCEN will also 

be able to collect more data, producing over three times the number of records collected by 

FY 2022 than in FY 2018, thus providing invaluable information for investigative leads. This 

data will lead to enhanced identification of enforcement and investigative leads as well as 

strategic trends and patterns.
FinCEN - 8

1.3 – Operating Levels Table

Dollars in Thousands

Financial Crimes Enforcement Network (FinCEN) FY 2018 FY 2019 FY 2020

Object Classification Enacted Annualized CR Request

11.1 - Full-time permanent 42,136 42,136 45,582

11.3 - Other than full-time permanent 408 408 408

11.5 - Other personnel compensation 205 205 205

11.9 - Personnel Compensation (Total) 42,749 42,749 46,195

12.0 - Personnel benefits 12,260 12,260 13,313

Total Personnel and Compensation Benefits $55,009 $55,009 $59,508

21.0 - Travel and transportation of persons 630 630 767

23.1 - Rental payments to GSA 4,151 4,151 4,558

23.2 - Rental payments to others 40 40 42

23.3 - Communications, utilities, and miscellaneous charges 1,705 1,705 1,739

24.0 - Printing and reproduction 162 162 153

25.1 - Advisory and assistance services 1,097 1,097 1,097

25.2 - Other services from non-Federal sources 17,278 17,278 20,916

25.3 - Other goods and services from Federal sources 9,698 9,698 9,496

25.6 - Medical care 174 174 174

25.7 - Operation and maintenance of equipment 17,811 17,811 18,429

26.0 - Raw Materials 333 333 331

31.0 - Equipment 6,915 6,915 7,489

Total Non-Personnel $59,994 $59,994 $65,192

New Budgetary Resources $115,003 $115,003 $124,700

FTE 281 333 360

FY 2018 shows actual FTE usage. This column reflects levels appropriated in P.L. 115-141 Consolidated Appropriations Act, 2018. 

For further details on the execution of these resources see the 2020 Budget Appendix chapter for the Department of the Treasury.
FinCEN - 9

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 for official reception and representation expenses; 

and for assistance to Federal law enforcement agencies, with or 

without reimbursement, $124,700,000, of which not to exceed 

$34,335,000 shall remain available until September 30, 2022.

Note.—A full-year 2019 appropriation for this account was not 

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

assumes this account is operating under the Continuing 

Appropriations Act, 2019 (Division C of P.L. 115–245, as 

amended). The amounts included for 2019 reflect the annualized 

level provided by the continuing resolution.

E – Legislative Proposals

FinCEN has no legislative proposals.
FinCEN - 10

Section II – Annual Performance Plan and Report

A – Strategic Alignment

FinCEN supports the Treasury Strategic Goal 3: Enhance National Security and Goal 5: Achieve 

Operational Excellence. In Strategic Goal 3, FinCEN supports the following Treasury Strategic 

Objectives: 3.1 Strategic Threat Disruption – Identify, disrupt, and dismantle priority threats to 

the U.S. and international financial system and Treasury Strategic Objective 3.2 Anti-Money 

Laundering/Combating Financing of Terrorism (AML/CFT) Framework – Identify and reduce 

vulnerabilities in the U.S. and international financial system to prevent abuse by illicit actors.

In FY 2018, FinCEN had several noteworthy accomplishments highlighted below:

• Resolved three civil enforcement actions against financial institutions that violated the BSA, 

which resulted in the assessment of civil money penalties against two depository institutions 

and one casino.

• Conducted four virtual currency exams, including the first Federal examination of the 

world’s largest money transmitter. 

• Issued advisories to the financial community on potential fraudulent activity related to 

disaster relief efforts; on how North Korea used front and trade companies to launder funds 

to finance its nuclear and ballistic missile programs; and on the results of the Financial 

Action Task Force plenary, including a reminder of regulatory obligations with respect to 

Iran and North Korea. 

• Issued an advisory to U.S. financial institutions highlighting the connection between corrupt 

senior foreign political figures and their enabling of human rights abuses. 

• Issued two Patriot Act Section 311 actions—one against the China-based Bank of Dandong, 

to further restrict North Korea’s access to the U. S. financial system, and the other against 

ABLV, a Latvian Bank involved in international fraud and sanctions evasion activity. Issued 

letters to gain greater transparency to potential threats and support investigations that resulted 

in the collection of over 34 million transaction records.
FinCEN - 11

B – Budget and Performance by Budget Activity

2.1.1 – BSA Administration and Analysis Resources and Measures

Dollars in Thousands

 Resource Level FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020

Actual Actual Actual Actual Actual Annualized CR Request

Appropriated Resources $112,000 $112,000 $112,979 $115,003 $115,003 $115,003 $124,700

Reimbursables Resources $3,000 $3,000 $3,000 $3,000 $3,000 $3,000 $3,000

Budget Activity Total $115,000 $115,000 $115,979 $118,003 $118,003 $118,003 $127,700

279 276 279 275 281 333 360

Workload Output / Activity FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 Est FY 2019 FY 2020 

Actual Actual Actual Actual Actual Estimates Request

Number of SARs filed 1,924,404 2,118,092 2,316,550 2,401,896 2,537,230 2,611,520 2,723,096

Number of total BSA reports filed 19,171,376 19,147,588 19,244,824 19,322,891 20,404,002 20,671,294 20,942,088

Number of BSA database users 11,198 10,166 10,883 11,452 11,679 12,150 12,514

Measure FY 2014 FY 2015 FY 2016 FY 2017 FY 2018 FY 2018 FY 2019 FY 2020

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 **

N/A B 95 92 95 90 95 95

Percentage of Domestic Law 

Enforcement and Regulators Who 

Assert Queried BSA Data Led to 

Detection and Deterrence of Illicit 

Activity **

80 81 83 86 85 86 86 87

Percentage of Users Satisfied with 

FinCEN Information Sharing Systems N/A 78 80 87 86 84 84 84

Percentage of Customers that Find 

Their Contact and Information Sharing 

Made a Beneficial Contribution 

Towards the Detection and 

Deterrence of Illicit Activity*

N/A 89 91 90 91 90 DISC DISC

Percent of financial regulators who 

find FinCEN’s enforcement and 

compliance efforts effective*

N/A N/A N/A 91 88 90 DISC DISC

**Performance measure names were modified from previous years to clarify the purpose of the measures. However, the method of collection and analysis remains 

consistant.

FTE (Actual)

*FinCEN will discontinue this performance measure in FY 2019 due to more concentrated focus on outcome measures. 
FinCEN - 12

BSA Administration and Analysis Budget and Performance

($124,700,000 from direct appropriations, $3,000,000 from reimbursable resources):

Description of Performance:

FinCEN measures the percentage of domestic law enforcement and foreign FIUs who assert that 

the analytic products they used led to detection and deterrence of illicit activity. This 

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

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

unknown information. In FY 2018, 95 percent found the analytic products and research had 

impact on the investigations, surpassing FY 2018 target of 90 percent. FinCEN was able to 

achieve this performance by concentrating on expanding product dissemination, increasing 

outreach to customers of its intelligence products, and improving processes to obtain feedback 

about product usefulness. The FY 2019 and FY 2020 targets are set at 95 percent. Maintaining 

this high level of performance will be a challenge due to anticipated increases in volume of BSA 

reports filed and evolving threats to the financial system.

FinCEN monitors the percentage of domestic law enforcement and regulators who assert queried 

BSA data led to detection and deterrence of illicit activity. This performance measure looks at 

the value of BSA 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 2018, FinCEN narrowly missed its 

target of 86 percent with 85 percent of users finding value from the data. FinCEN will work 

toward increasing its FinCEN Portal/FinCEN Query training efforts to provide more users with 

the knowledge needed in order to better utilize both FinCEN Portal and FinCEN Query. In 

FY 2019, the target is set at 86 percent and 87 percent in FY 2020. 

FinCEN tracks the percentage of users satisfied with FinCEN information sharing systems. This 

measure is based on survey responses and represents user satisfaction with the BSA E-Filing 

System, FinCEN Query, and the Egmont Secure Web. Starting with the 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 13 years of historical 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 more readily access BSA information and better enables them to conduct 

investigations more efficiently and effectively. In FY 2018, FinCEN exceeded its target of 84 

percent with 86 percent of the users satisfied with information sharing systems, which far 

exceeds the federal government benchmark of 70 percent for customer satisfaction. FinCEN 

attributes this performance to the usefulness of the data it provides, users’ increased familiarity 

with systems which are in a steady operational state, and its knowledgeable and courteous user 

support staff. In FY 2019, FinCEN will keep the target at 84 percent because it plans to make 

modest updates to its information sharing systems. FinCEN does intend to make some more 

impactful modifications in FY 2020, but will keep the target at 84 percent due to the learning 

curve associated with the changes being introduced to the user base. 
FinCEN - 13

FinCEN monitors the percentage of customers that find their contact and information sharing 

made a beneficial contribution toward the detection and deterrence of illicit activity. This 

measure was based on the survey responses of customers who have had contact with FinCEN to 

exchange information, including industry, regulators, and law enforcement, both domestic and 

foreign. This is a composite measure that consists of the following questions: whether the call 

center guidance response was understandable; rating the usefulness of the 314(a) requests that 

FinCEN processed on behalf of the customer’s agency for investigations of financial crimes or 

money laundering; level of satisfaction with the information sharing the customer has with 

FinCEN; and over the past 12 months, the customer’s satisfaction level with FinCEN. This is a 

meaningful measure as it tracks FinCEN’s efforts to share high quality financial intelligence in a 

timely manner and ongoing efforts to solicit useful feedback from key stakeholders. In FY 2018, 

FinCEN surpassed its target of 90 percent with 91 percent finding the information sharing 

helpful. FinCEN will discontinue this performance measure in FY 2019 due to more 

concentrated focus on outcome measures. 

FinCEN tracks the percentage of financial regulators who find FinCEN’s enforcement and 

compliance efforts effective. This is a survey measure of the financial regulators that have an 

information sharing agreement with FinCEN. This measure tracks the effects of FinCEN’s 

compliance and enforcement efforts. The survey tracks the impact of prior enforcement actions 

on levels of compliance and incorporate questions that gauge improved cooperation, compliance,

and consistency in the application of the BSA. For FY 2018, the percentage of financial 

regulators finding FinCEN’s enforcement and compliance efforts effective was 88 percent. This 

missed the FY 2018 target of 90 percent. FinCEN consistently scored above 90 percent in most 

individual elements, with the exceptions of “cooperation” and “compliance.” There are many 

other factors that affect compliance within the industry, in addition to the deterrent effect and the 

public narratives of enforcement actions. To improve this factor, FinCEN intends to continue its 

focus on compliance efforts in the industry, including outreach, ongoing dialogue, and 

examinations. FinCEN will discontinue this performance measure in FY 2019 due to a more 

concentrated focus on outcome measures. 

C – Changes in Performance Measures 

 Performance Measure or Indicator Proposed Change and Justification

Percentage of customers that find their 

contact and information sharing made a 

beneficial contribution toward the detection 

and deterrence of illicit activity 

(discontinue)

FinCEN proposes to stop reporting this metric 

in the CJ/BIB due to more concentrated focus 

on outcome measures.

Percent of financial regulators who find 

FinCEN’s enforcement and compliance 

efforts effective (discontinue)

FinCEN proposes to stop reporting this metric 

in the CJ/BIB due to more concentrated focus 

on outcome measures.
FinCEN - 14

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 20.4 million filings in FY 2018. To 

successfully fulfill its mission, FinCEN relies on secure, advanced information technology (IT) 

to manage the collection, processing, storage, and dissemination of BSA information that 

contributes to the soundness and confidence in America’s financial system.

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

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

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

laundering, and unravel terrorist financing networks. FinCEN’s IT strategy focuses on the 

critical need to improve the quality and accessibility of its data and increase responsiveness to 

stakeholders by maintaining and building upon flexible and innovative technical solutions. The 

entire lifecycle cost of the BSA IT Modernization investment, which includes the year the 

investment started (2010) through BY+4 (2024), is $410.296 million (including FTE) and the 

FY 2020 cost is projected at $35.3 million (including FTE).

A summary of capital investment resources, including major information technology and nontechnology investments can be found at:

http://www.treasury.gov/about/budget-performance/Pages/summary-of-capital-investments.aspx

This website also contains a digital copy of this document.