Financial Crimes Enforcement Network

Program Summary by Budget Activity

Dollars in thousands

Appropriation FY 2011 FY 2012 FY 2013 FY 2012 TO FY 2013

 Enacted Enacted Request $ Change % Change

BSA Administration and Analysis $101,491 $110,788 $102,407 ($8,381) (7.6%)

Regulatory Support Programs $9,297 $0 $0 $0 NA

Subtotal, Financial Crimes Enforcement 

Network $110,788 $110,788 $102,407 ($8,381) (7.6%)

Offsetting Collections - Reimbursables $20,000 $3,000 $3,000 $0 0%

Total Program Operating Level $130,788 $113,788 $105,407 ($8,381) (7.4%)

Direct FTE 327 327 322 (5) (1.5%)

Reimbursable FTE 1 1 1 0 0%

Total FTE 328 328 323 (5) (1.5%)

Summary

The mission of FinCEN, a Treasury bureau 

reporting to the Under Secretary for Terrorism 

and Financial Intelligence, is to enhance the 

integrity of financial systems by facilitating 

the detection and deterrence of financial crime. 

FinCEN fulfills its mission, goals and 

priorities by administrating the Bank Secrecy 

Act (BSA); furnishing analytical and financial 

expertise to support law enforcement 

investigations and prosecutions; determining

emerging trends in money laundering and 

other financial crimes; and serving as the 

nation’s financial intelligence unit (FIU). 

In FY 2013, FinCEN’s priorities are to: 

 Support the Presidential goal of 

encouraging economic growth by 

safeguarding the financial systems from 

abuse and promoting transparency in the 

U.S. and international financial systems; 

 Enhance BSA regulatory compliance and 

enforcement through increased reliance on 

state regulatory agencies, strengthened 

relationships with law enforcement, and 

implementation of compliance strategies 

for newly regulated industries; 

 Lead efforts to coordinate federal, state, 

and local efforts to combat fraud; 

 Engage with priority countries and 

international bodies to strengthen 

mechanisms for global information 

exchange; and 

 Efficiently manage the collection, 

processing, and retrieval of BSA data

under the BSA IT Modernization program.

In this environment of declining resources, 

FinCEN is uniquely positioned at the 

intersection of financial industry, regulators, 

law enforcement agencies, and global partners. 

FinCEN is able to network these different 

perspectives to bring comprehensive insights 

to the detection and deterrence of financial 

crime. This unique position allows FinCEN to 

develop and support multiple partnerships that 

have a broad national and international impact. 
FinCEN FY 2013 Budget Highlights

Dollars in thousands

Financial Crimes Enforcement 

Network

FTE Amount

FY 2012 Enacted 327 $110,788

Changes to Base:

Adjustment to Request: 8 $0

Adjustment for Transitioned 

BSA Collection and Processing 

Activities

8 $0

Maintaining Current Levels 

(MCLs):

- $930

Maintaining Current Levels - $930

Efficiency Savings: (14) ($6,232)

Eliminate IT Legacy Systems - ($3,047)

Administrative Staffing 

Efficiencies

(14) ($2,168)

Regulatory Efficiency Savings - ($1,017)

Subtotal FY 2013 Changes to 

Base

(6) ($5,302)

Total FY 2013 Base 321 $105,486

Program Changes:

Program Decreases: (23) ($9,871)

Redirect IRS Reimbursement 

for BSA Compliance

- ($5,925)

Reduce Intelligence Support to 

External Agencies

(6) ($968)

Reduce Field Law 

Enforcement Support

(3) ($683)

Program Staff Attrition (14) ($2,295)

Reinvestments: 24 $6,792

BSA Collection Processing and 

Retrieval Functions from IRS 

Reimbursement

12 $2,675

Improve Industry Compliance 

and Enforcement from IRS 

Reimbursement

12 $2,525

Cross Border System from IT 

Legacy System

- $1,592

Total FY 2013 Request 322 $102,407

FY 2013 Budget Adjustments

FY 2012 Likely Enacted

The FY 2012 enacted direct appropriation for 

FinCEN is $110,788,000.

Adjustment to Request

Adjustment for Transitioned BSA Collection 

and Processing Activities +$0 / +8 FTE

FinCEN will begin in FY 2012 to implement 

the transition of BSA collection and 

processing activities that have been previously 

performed by the IRS. Going forward, 

FinCEN will be responsible for BSA 

collection and processing, in conjunction with 

FinCEN’s BSA IT Modernization. With this 

FTE adjustment, FinCEN will begin the 

consolidation of caller inquiries previously 

fielded by the IRS. FinCEN anticipates an

increased call volume due to the

implementation of the new unified BSA forms

and mandated electronic filing. These 

activities are funded by redirecting $1,725,000 

previously reimbursed to IRS since FY 2001 

for data entry and related support for money 

services business (MSB) registration and 

suspicious activity reporting.

Maintaining Current Levels (MCLs) 

Maintaining Current Levels +$930,000 / +0 

FTE

Funds are requested for inflation adjustments 

(1.7 percent) in non-labor expenses such as 

GSA rent adjustments, postage, supplies, 

equipment, health benefits, and the increase in 

Federal Employees Retirement System 

participation. Funds are also requested for the 

proposed 2013 pay raise (0.5 percent).

Efficiency Savings

Eliminate IT Legacy Systems -$3,047,000 / +0 

FTE

This eliminates funding to maintain the legacy 

Secure Outreach and BSA E-Filing Systems. 

In FY 2012 and 2013, FinCEN will roll out 

new capabilities for the collection, processing 

and analysis of BSA data as part of its IT 

Modernization.

Administrative Staffing Efficiencies 

-$2,168,000 / -14 FTE

These staffing efficiencies will be achieved 

through absorption of workload associated 

with positions lost through attrition and using 

a cross service provider, where cost effective.

Regulatory Efficiency Savings -$1,017 / +0 

FTE

FinCEN will achieve efficiency savings 

through targeted regulatory support efforts, 

centralization of MSB outreach activities, and 

change in distribution methodology for MSB 

brochure materials. The impact of these 

reductions will be mitigated through future 

consolidation of call centers; centralization of 

outreach activities; additional outreach support 
by FinCEN staff; and greater reliance on 

FinCEN’s public website to distribute MSB 

materials, supporting Treasury’s paperless 

initiative.

Program Decreases

Redirect IRS Reimbursement for BSA 

Compliance -$5,925,000 / +0 FTE

This decrease will redirect funding provided to 

the IRS for BSA compliance by FinCEN to 

carry out some delegated examinations for 

compliance with FinCEN regulations. 

Activities in support of BSA compliance are 

currently funded primarily through IRS direct 

appropriations; however, FinCEN also 

provides funding through an annual 

reimbursement to IRS. The financial 

institutions currently subject to examination by 

the IRS are collectively referred to as nonbank financial institutions (NBFIs). Over the 

last 12 years, the BSA compliance 

examination program has evolved, along with 

IRS’s direct appropriation and organization

structure for BSA compliance. In addition, 

FinCEN’s legislative proposal would allow the 

bureau to rely on one or more financial 

supervisors in each of the states to carry out 

BSA compliance examinations for their 

respective regulated institutions.

Reduce Intelligence Support to External 

Agencies -$968,000 / -6 FTE

This decrease will reduce analytical support to 

external customers in support of their national 

security, counter terrorism financing, and law 

enforcement matters. FinCEN will continue to 

carry-out limited case support and support to 

FinCEN's analytical initiatives that require 

national security information. FinCEN will 

also provide access to BSA information for 

some external agencies through appropriate 

information sharing protocols.

Reduce Field Law Enforcement Support 

-$683,000 / -3 FTE

Reductions are identified from discontinuance 

of a liaison position at the Federal Law 

Enforcement Training Center (FLETC), and 

from decreases in field positions located in 

High Intensity Financial Crime Areas

(HIFCAs). FinCEN will continue to support 

law enforcement from its headquarters. 

FinCEN will continue to carry out limited case 

support and support FinCEN's analytical 

initiatives that require national security 

information.

Program Staff Attrition -$2,295,000 / -14 FTE

This reduction will be taken across several 

FinCEN program areas. FinCEN will evaluate 

open positions for possible absorption of 

workload associated with positions lost 

through attrition.

Reinvestments

BSA Collection Processing and Retrieval 

Functions from IRS Reimbursement 

+$2,675,000 / +12 FTE

This reinvestment is needed to complete the 

transition of BSA collection and processing 

activities started in FY 2012 from IRS to 

FinCEN. The BSA IT Modernization program 

provides the technology structure to allow 

FinCEN to mandate BSA E-filing and 

eliminate most of the current BSA paper 

processing activities currently performed on 

FinCEN’s behalf by the IRS. These changes 

necessitate consolidation and transfer of 

remaining activities to FinCEN to provide an 

efficient structure for responding to filer and 

caller inquires related to BSA forms 

submission (except Foreign Bank and 

Financial Accounts (FBAR) and Form 8300 

inquiries, for which IRS will retain 

responsibility due to its Title 26 tax 

implications). This consolidation is consistent 

with FinCEN’s regulatory role as 

administrator of the BSA.

Improve Industry Compliance and 

Enforcement from IRS Reimbursement 

+$2,525,000 / +12 FTE

This reinvestment will allow FinCEN to better 

carry out its responsibilities to coordinate 

among all financial supervisory agencies 

exercising delegated examination authority, as 
well as state supervisory agencies and the IRS. 

Several changes have prompted FinCEN’s 

need and ability to better coordinate NBFI 

compliance examinations. First, the number of 

NBFIs has increased over the last decade with 

the implementation of BSA requirements for 

additional industries. Second, the enhanced 

analytic capabilities provided by the BSA IT 

Modernization will enable a more risk-based 

examination schedule and a more consistent 

and centralized approach to compliance across 

different industries. Third, a legislative 

proposal in FinCEN’s budget provides 

authority to rely on examinations conducted by 

state regulators for NBFIs lacking a federal 

regulator. FinCEN would increase reliance on 

state examinations where appropriate, 

allowing for better targeting of IRS and 

FinCEN resources on areas of greater risk.

Cross Border System from IT Legacy System 

+$1,592,000 / +0 FTE

This reinvestment will fund operations and 

maintenance for the foundational infrastructure 

that captures cross border electronic funds 

transfer information (CBEFT). CBEFT

requirements and solutions have evolved since 

the funding started in FY 2008 as reflected in 

the proposed rulemaking published in 

September 2010, which based on discussions 

with the IRS, included the addition of taxpayer 

identification numbers as part of the 

information to be reported under the rule.

Explanation of Budget Activities

BSA Administration and Analysis 

($102,407,000 from direct appropriations, 

$3,000,000 from reimbursable resources)

The programs funded by this budget activity 

support the Treasury strategic goal to protect 

our national security through targeted financial 

actions. 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, managing the information reported by the 

regulated industries, as well as BSA 

compliance of non-bank financial institutions. 

Analytical programs include support to U.S. 

law enforcement and international FIUs in 

combating financial fraud and crime by 

facilitating the exchange of investigative 

information, including with foreign 

counterpart FIUs; identifying foreign and 

domestic financial fraud, money laundering, 

and terrorist financing trends, patterns, and 

techniques; and liaison with and support of 

intelligence initiatives within the intelligence 

community and within Treasury. This activity 

also incorporates efforts to support large-scale, 

complex law enforcement investigations 

involving financial fraud, terrorist financing, 

money laundering, and other financial crimes. 

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 authorized law 

enforcement, regulatory, and intelligence 

agencies direct access to BSA information.

Global programs include support to

international initiatives to educate other 

jurisdictions about the BSA regulatory regime; 

work to establish international anti-money 

laundering/counter-terrorist financing 

regulatory standards and norms; and efforts to 

improve the expertise and capabilities of 

personnel with anti-money laundering/counterterrorist financing missions.

Regulatory Support ($0 from direct 

appropriations)

This budget activity was eliminated in FY 

2012.

Legislative Proposals

FinCEN is proposing three technical 

amendments to Titles 31 and 12 (sections 116 

to 118 of the proposed Treasury administrative 

provisions) that would make improvements in 
two important areas. The first and second 

amendments provide authority to rely on 

examinations conducted by state supervisory 

agencies for NBFIs lacking a federal regulator, 

which would capture most nonbank financial 

institutions currently subject to IRS 

examination. The third amendment increases 

information sharing between FinCEN and 

counterpart anti-money laundering/counterterrorist financing regulators. Specifically, 

this amendment provides consistency between 

how FinCEN shares information in its capacity 

as a regulator and information sharing that 

currently exists between federal financial 

regulators and their foreign counterparts.

FinCEN Performance by Budget Activity

Budget Activity Performance Measure FY 2009 FY 2010 FY 2011 FY 2012 FY 2013

Actual Actual Actual Target Target

BSA Administration 

and Analysis

Percentage of customers finding the FinCEN 

data provides valuable information towards the 

detection and deterrence of financial crime

N/A 87.0 89.0 86.0 90.0

BSA Administration 

and Analysis

Percentage of domestic law enforcement finding 

FinCEN's analytic reports contribute to the 

detection and deterrence of financial crime

N/A 80.0 86.0 80.0 80.0

BSA Administration 

and Analysis

Percentage of foreign FIUs finding FinCEN's 

analytic reports provide valuable information 

towards the detection and deterrence of 

financial crime

N/A 90.0 92.0 90.0 90.0

BSA Administration 

and Analysis

Percentage of regulatory helpline customers 

understanding BSA guidance

94.0 92.0 92.0 90.0 90.0

Key: DISC - Discontinued and B - Baseline

Description of Performance

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 with FinCEN’s 

regulations. In FY 2011, FinCEN’s goal was 

to maintain a 90 percent satisfaction level and 

FinCEN met its target with 92 percent.

In the analytical area, FinCEN supports 

domestic law enforcement and international 

FIU partners by providing analyses of BSA 

information, and measures the percentage of 

customers finding FinCEN’s analytic reports 

highly valuable. The following two measures 

closely tie to how BSA information is used by 

law enforcement and foreign FIUs to identify, 

investigate, and prevent abuse of the financial 

system. The first measure looks at the value 

provided to the domestic law enforcement 

community. In FY 2010, FinCEN baselined 

this performance measure with 80 percent 

rating the analytic products as valuable. In FY 

2011, 86 percent of the domestic law 

enforcement respondents rated the analytic 

products as valuable. The second measure 

tracks the value of the analytic reports to 

foreign FIU customers. In FY 2010, FinCEN 

set a baseline for this measure of 90 percent. 

In FY 2011, 92 percent of foreign FIUs rated 

the analytic products as valuable.

In the efficient management, safeguarding, and 

use of BSA information, FinCEN began 

tracking the value of the BSA information to 

law enforcement and regulatory agency users 

with direct access to the BSA data. The 

survey 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, and 

provided information for an investigative or 

examination report. The FY 2011 actual for 

the percentage of customers finding the BSA 

data provides valuable information towards the 

detection and deterrence of financial crime 

was 89 percent.