Department of the Treasury 

Financial Crimes Enforcement 

Network 

Congressional Budget 

Justification and Annual 

Performance Plan and Report 

FY 2021 
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 – Object Classification (Schedule O) Obligations ................................................................ 7

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

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

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

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

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

D – Evidence-Building Activity ............................................................................................... 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 

The FY 2021 President’s Budget requests additional resources totaling $963,000 and provides 

$2,300,000 for two critical program areas and program decreases totaling $2,864,000. 

Specifically, FinCEN will enhance its national security capacity, which includes continuous 

expansion of its efforts to combat cybercrime and cryptocurrency threats and strengthening the 

inspection and training efforts to ensure the proper stewardship and on-going protection of 

sensitive national security information. 

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). 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 164 partner countries; 

 Receiving millions of new financial reports each year; 

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

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

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

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

industry. 
FinCEN – 4 

1.1 – Appropriations Detail Table 

Dollars in Thousands 

 FY 2019 FY 2020 FY 2021 FY 2020 to FY 2021 

Appropriated Resources Operating Plan Enacted Request % Change 

New Appropriated Resources FTE AMOUNT FTE AMOUNT FTE AMOUNT FTE AMOUNT 

BSA Administration and Analysis 271 $117,800 300 $126,000 345 $126,963 15.0% 0.8% 

Subtotal New Appropriated Resources 271 $117,800 300 $126,000 345 $126,963 15.0% 0.8% 

Other Resources 

Reimbursable 2 $1,771 1 $3,000 1 $3,000 NA 0.0% 

Recoveries from Prior Years 0 $34 0 $500 0 $500 NA 0.0% 

Unobligated Balances from Prior Years 0 $37,967 0 $27,000 0 $28,000 NA 3.7% 

Subtotal Other Resources 2 $39,772 1 $30,500 1 $31,500 0.0% 3.3% 

Total Budgetary Resources 273 $157,572 301 $156,500 346 $158,463 15.0% 1.3% 

FY 2019 Other Resources and Full-time Equivalents (FTE) reflect actuals. 

1.2 – Budget Adjustments Table 

Dollars in Thousands 

 FTE Amount 

FY 2020 Enacted 300 $126,000 

Changes to Base: 

Maintaining Current Levels (MCLs): 0 $2,827 

Pay Annualization (3.1% average pay raise) 0 $380 

Pay Raise (1.0% average pay raise) 0 $390 

FERS Contribution Increase 0 $524 

Non-Pay 0 $1,533 

Non-Recurring Costs 0 ($1,300) 

TBML Risk Assessment 0 ($1,300) 

Other Adjustments: 37 $0 

Technical FTE Adjustment 37 $0 

Subtotal Changes to Base 37 $1,527 

FY 2021 Current Services 337 $127,527 

Program Changes: 

Program Decreases 0 ($2,864) 

 Programmatic Contract and Equipment Reductions 0 ($2,864) 

Program Increases: 8 $2,300 

 Bolstering BSA Data Protection 5 $1,481 

Building Out FinCEN's Virtual Currency and Cyber 

Threat Mitigation Program 3 $819 

FY 2021 President's Budget Request 345 $126,963 

C – Budget Increases and Decreases Description 

Maintaining Current Levels (MCLs) ........................................................+$2,827,000 / +0 FTE 

Pay Annualization (3.1%) +$380,000 / +0 FTE: 

Funds are requested for annualization of the January 2020 3.1% average pay raise. 

Pay Raise (1.0% in 2021) +$390,000 / +0 FTE 

Funds are requested for a 1.0% average pay raise in January 2021. 
FinCEN – 5 

FERS Contribution Increase +$524,000 / +0 FTE 

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

effective FY 2021. 

Non-Pay +$1,533,000 / +0 FTE 

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

and equipment. 

Non-Recurring Costs..............................................................-$1,300,000 / -0 FTE 

TBML Risk Assessment -$1,300,000 / -0 FTE 

Completion of Trade-Based Money Laundering (TBML) risk assessment. 

Other Adjustments.........................................................................+$0 / +37 FTE 

Technical FTE Adjustment +$0 / +37 FTE 

This adjustment reflects FTEs in FinCEN’s multi-year hiring plan, which is beginning 

implementation in FY 2020. 

Program Decreases .....................................................................................-$2,864,000 / -0 FTE 

Programmatic Contract and Equipment Reductions -$2,864,000 / -0 FTE 

This reduction will be taken through evaluation of potential decreases or changes in proposed 

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

renewal process to absorb this reduction. 

Program Increases ....................................................................................+$2,300,000 / +8 FTE 

Bolstering BSA Data Protection +$1,481,000 / +5 FTE 

This funding will allow FinCEN to support an enhancement in BSA data inspections and training 

efforts. In order to bolster the ability to protect BSA data collected, FinCEN will strengthen its 

inspections program to include internal, external, and bulk data usage; enhance its proactive 

engagement for preventative measures; and increase education and training efforts for the over 

460 federal, state, and local agencies across the country with whom FinCEN maintains data 

access Memoranda of Understanding (MOUs) and their over 12,700 authorized users. 

Safeguarding the BSA database from misuse is a critical obligation, and FinCEN needs to make 

on-site inspections of its MOU holders a priority. With additional funding, FinCEN will move to 

a primarily on-site inspection posture to enhance our visibility into individual agencies’ 

compliance with the obligations set forth in their MOUs. This effort is very much in furtherance 

of FinCEN’s obligation to safeguard the BSA database from misuse and will allow FinCEN to 

increase the number of routine on-site inspections performed. 

In addition to expanding FinCEN’s capabilities to inspect data access activities, there is also a 

need to increase the training and outreach initiatives. From FY 2014 to FY 2018 there was an 18 

percent increase in BSA data access MOUs, and FinCEN expects this percentage to steadily 

increase annually. Furthermore, FinCEN receives on average 120 access requests per year. As 

we anticipate an increase in MOUs in the future commensurate with historical growth patterns, 

there is a need for more training resources to cover BSA data security and proper use of BSA 

data for the corresponding increase in users. In order for FinCEN to keep up with the increasing 
FinCEN – 6 

needs of our stakeholders, we must be readily available to conduct substantive outreach and 

provide comprehensive financial analysis training. Better understanding of complex financial 

schemes translates into better use of BSA data, which encourages more responsible behavior 

when accessing the data. It will also increase FinCEN’s ability to provide on-going, substantive 

training and outreach to our law enforcement partners on myriad issues of national security 

importance in an effort to increase their awareness and enhance their traditional methods of 

utilizing the BSA to investigate illicit finance. As investigators become more adept at 

manipulating BSA data, more sophisticated cases of criminal wrongdoing will be brought to 

justice. Additionally, more meaningful feedback provided to regulated institutions that are 

subject to BSA reporting requirements ultimately lends to better reporting by the institutions 

themselves. 

Increased access to BSA data creates increased risk of improper use of the data, including 

unauthorized disclosures. Training addresses this knowledge gap for stakeholders and assists 

them in effectively manipulating the BSA data to properly support their investigations. This 

effort also assists FinCEN in maintaining a close and continual working relationship with its 

broad universe of stakeholders. These additional resources will allow FinCEN to ensure all of its 

users are fulfilling their responsibility to properly use and protect BSA data. 

Building Out FinCEN’s Virtual Currency and Cyber Threat Mitigation Program +$819,000 / +3 

FTE 

These funds will allow for international capacity building to ensure that accessibility of critical 

information exists for investigations that include an international component. The utilization of 

software tools will allow FinCEN to double the number of virtual currencies analyses, 

corroborate findings, and increase big data analytics capability, allowing for automated analytics 

and visualization of financial and cyber data. The program enhancement strengthens direct 

support for law enforcement cases to 130 cases per year, the development of 37 strategic 

intelligence products, and the provision of 50 training sessions per year. 

The FY 2021 funds will also allow FinCEN to respond to an increasing number of law 

enforcement requests for operational support regarding domestic and global cyber-enabled 

financial crimes, including efforts into the use of virtual currency to facilitate such crimes. This 

will enable FinCEN to conduct intelligence and law-enforcement driven responses to 

international and domestic financial threat incidents. The enhancement will also assist FinCEN’s 

ongoing efforts to recover funds stolen by cyber means in fraud and virtual currency exchange 

thefts. Based on metrics developed by law enforcement partners, FinCEN estimates that it will 

be able to recover approximately 60 percent of funds stolen domestically and maintain its current 

international recovery rate at 50 percent. 

Lastly, the funding will directly support FinCEN’s coordination with other international 

jurisdictions as they advance their efforts to establish their own capabilities to address virtual 

currency and cyber threats through training and capacity building, analytical development, and 

information sharing initiatives. 
FinCEN – 7 

1.3 – Object Classification (Schedule O) Obligations 

Dollars in Thousands 

 FY 2019 FY 2020 FY 2021 

Object Classification 

Actual 

Obligations 

Estimated 

Obligations 

Estimated 

Obligations 

11.1 - Full-time permanent 35,696 41,247 47,434 

11.3 - Other than full-time permanent 101 150 150 

11.5 - Other personnel compensation 770 822 845 

11.9 - Personnel Compensation (Total) 36,567 42,219 48,429 

12.0 - Personnel benefits 11,352 12,374 14,231 

Total Personnel and Compensation Benefits $47,919 $54,593 $62,660 

21.0 - Travel and transportation of persons 658 767 816 

22.0 - Transportation of things 2 0 0 

23.1 - Rental payments to GSA 4,193 4,913 4,971 

23.2 - Rental payments to others 49 50 51 

23.3 - Communications, utilities, and miscellaneous charges 1,703 2,100 2,137 

24.0 - Printing and reproduction 62 62 65 

25.1 - Advisory and assistance services 1,517 1,500 1,552 

25.2 - Other services from non-Federal sources 48,930 44,285 35,478 

25.3 - Other goods and services from Federal sources 13,531 7,903 10,143 

25.6 - Medical care 186 200 226 

25.7 - Operation and maintenance of equipment 9,210 9,100 9,497 

26.0 - Supplies and materials 251 270 278 

31.0 - Equipment 1,635 1,765 1,928 

Total Non-Personnel $81,927 $72,915 $67,142 

Total Obligations $129,846 $127,508 $129,802 

 

Full-time Equivalents (FTE) 273 301 346 

Amounts reflect obligations of annually appropriated resources, carryover balances, reimbursables, and transfers. 
FinCEN – 8 

D – Appropriations Language and Explanation of Changes 

Appropriations Language Explanation of Changes 

DEPARTMENT OF THE TREASURY 

BUREAU NAME 

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, 

[$126,000,000]$126,963,000, of which not to exceed 

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

[2022]2023. (Department of the Treasury Appropriations Act, 

2020.)

E – Legislative Proposals 

FinCEN has no legislative proposals. 
FinCEN – 9 

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 Framework – Identify and reduce vulnerabilities 

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

In FY 2019, FinCEN had several noteworthy accomplishments highlighted below: 

 Expand Supervision over Non-bank Financial Institutions

o Piloted a project to collect virtual currency sector data for identifying activity of illicit 

concern. 

o Successfully completed a pilot for identifying compliance risk among entities 

registered as money services businesses (MSBs) with FinCEN. The pilot used BSA 

data to risk-rate MSBs. FinCEN intends to expand this pilot to other sectors, and is 

currently in preliminary stages with casinos and Residential Mortgage Lenders and 

Originators (RMLOs). 

 Modernize, Streamline, and Simplify Regulatory Authorities

o Provided interpretive guidance to the regulated industry consolidating FinCEN 

regulations related to MSBs, explaining how they apply to convertible virtual 

currency (CVC) business models. 

o With the Federal Banking Agencies (FBAs), issued three joint statements on 1) 

sharing BSA resources; 2) encouraging innovative approaches to meeting Bank 

Secrecy Act/Anti-Money Laundering (BSA/AML) compliance obligations; and 3) 

emphasizing the risk-focused approach to examinations of banks’ BSA/AML 

compliance programs. 

o Created an AML Effectiveness Working Group in the BSA Advisory Group 

(BSAAG) to develop recommendations to enhance the AML regime by focusing on 

strategic AML priorities and realigning AML compliance practices to more 

effectively deter criminal activity. 

 Enhance Systems and Analytical Capabilities

o FinCEN also transitioned the final three BSA reports (Foreign Bank Account, 

Designation of Exempt Person, Cash over 10K Received in Trade/Business) to the 

Extensible Mark-Up Language (XML) industry format for electronic filing. 

 Expand Special Measures Efforts

o Issued special collections requests to dozens of financial institutions related to a range 

of illicit finance concerns including the Democratic People’s Republic of North 

Korea (DPRK), Iran, Venezuela, Third Party Money Launders, Transnational 

Organized Crime, and other illicit activity. FinCEN expects to receive in the order of 
FinCEN – 10 

50 million records in response to these requests, which will help to identify future 311 

targets and further map out broad illicit financial activity. 

o In coordination with interagency partners, FinCEN expanded the use of its 311 

authorities by investigating cases of drug trafficking and illicit financial activity in 

Venezuela and elsewhere in Latin America, proliferation of weapons of mass 

destruction in Asia, and other illicit activity in the Middle East and sub-Saharan 

Africa. 

 Financial Intelligence

o Increased support to cyber-related investigations, publishing more than 76 products 

ranging from Intelligence Assessments, Situation Reports, Investigative 

Memorandums, Flash Reports, and Spontaneous Disclosures, including a joint 

publication with law enforcement partners and a public product on Business Email 

Compromise (BEC). 

o Provided financial analyses supporting law enforcement efforts to combat 

fentanyl/opioid trafficking and Hizballah-related narcotics money laundering, and 

provided briefings and training to law enforcement on detecting and countering 

opioid trafficking. 

o Produced over 300 intelligence analyses or trend updates on threat actors, including 

transnational security threats (terrorism financing, Venezuela, Iran, and DPRK). 

 Expand Threat and Information Sharing

o Hosted four FinCEN Exchange events to enhance information sharing with financial 

institutions and provide them with important information regarding priority issues. 

o Completed three Egmont Information Exchange Working Group projects, producing 

two important Bulletins and a Report: a BEC Bulletin that was published for the 

public, a Human Trafficking Bulletin that was disseminated to Egmont members, and 

an Egmont Counter Terrorist Financing Project Report on lone actors and small cells. 

o Launched a pilot of the Rapid Response Program focusing on domestic wire transfers 

related to BEC. 

FinCEN’s FY 2020 and FY 2021 Priorities include: 

 Enhance efforts to identify and disrupt threats to financial system by increased tactical and 

strategic BSA-focused analytical products on terrorism, cyber and emerging technology 

threats; 

 Improve BSA framework through execution of priority initiatives with Federal Banking 

Agency, Bank Secrecy Act Advisory Group, BSA Value Project, and the Innovation 

Initiative; 

 Increase its international information sharing efforts with members of the Egmont Group of 

Financial Intelligence Units (FIU); 

 Continue to expand its investigative efforts with respect to foreign jurisdictions, financial 

institutions and classes of transactions of primary money laundering concern; 

 Partner with Functional Regulators to implement AML examination through an effective 

results-driven approach and participate in four examinations of covered financial institutions; 
FinCEN – 11 

 Bolster BSA Data Protection to enhance ability to protect BSA data collected through 

enhancements to BSA data inspections and training efforts. 

B – Budget and Performance by Budget Activity 

2.1.1 – BSA Administration and Analysis Resources and Measures 

Dollars in Thousands 

 FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2020 FY 2021 

 Resource Level Actual Actual Actual Actual Actual Enacted Request 

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

Reimbursable Resources $515 $1,721 $2,526 $2,198 $1,771 $3,000 $3,000 

Budget Activity Total $112,515 $114,700 $117,529 $117,201 $119,571 $129,000 $129,963 

Full-time Equivalents (FTE) 276 279 275 281 273 301 346 

The FY 2015 - FY 2019 appropriated resources represents the approved operating plan. The FY 2015 - FY 2019 columns represent realized 

resources for full-time equivalents and reimbursables.

Workload 

Output/Activity 

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2019 FY 2020 FY 2021 

Actual Actual Actual Actual Actual Estimate Estimate Estimate 

Number of SARs filed 2,118,092 2,316,550 2,401,896 2,537,225 2,698,841 2,689,459 2,850,826 3,021,876 

Number of total BSA 

reports filed 19,147,588 19,244,824 19,322,891 20,393,947 20,755,285 20,801,826 21,217,862 21,642,220 

Number of BSA users 10,166 10,833 11,452 11,739 12,801 12,326 12,942 13,589 

Performance Measure 

FY 2015 FY 2016 FY 2017 FY 2018 FY 2019 FY 2019 FY 2020 FY 2021 

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 

B 95% 92% 95% 92% 95% 90% 90% 

Percentage of Domestic 

Law Enforcement and 

Regulators Who Assert 

Queried BSA Data Led 

to Detection and 

Deterrence of Illicit 

Activity 

81% 83% 86% 85% 92% 86% 88% 89% 

Percentage of Users 

Satisfied with FinCEN 

Information Sharing 

Systems 

78% 80% 87% 86% 89% 84% 84% 85% 

Key: B - Baseline 

 
FinCEN – 12 

BSA Administration and Analysis Budget and Performance 

($126,963,000 from direct appropriations, $3,000,000 from reimbursable sources): 

Description of Performance: 

The continued increase in valuable BSA data demands the continued expansion of analysis 

capability and supporting technology to utilize this data to its full capacity. The increases in 

BSA data and the demand for this data informed the requested program changes. 

FinCEN conducts three annual surveys of the BSA database and information sharing systems’ 

users on the utility and value of FinCEN’s information, analysis, and systems. The results 

provide valuable feedback on FinCEN’s performance safeguarding the financial system from 

illicit use, combatting money laundering, and promoting national security. 

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

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

unknown information. In FY 2019, 92 percent found the analytic products and research had 

impact on the investigations, narrowly missing the target of 95 percent. Even though the target 

was narrowly missed, FinCEN was able to achieve this high level of performance by 

continuously evaluating and enhancing the processes that FinCEN uses to ensure that 

intelligence products meet the demands of its domestic and international stakeholders. The 

increased outreach and feedback to and from FinCEN’s users of its intelligence products resulted 

in introducing new types of intelligence products which focused on high-profile actors and illicit 

finance networks. These and other products also leverage new data obtained through FinCEN’s 

unique authorities, making the analyses in these products more timely, informative and 

actionable. The FY 2020 and FY 2021 targets are set at 90 percent. Due to the number and 

increasing sophistication of domestic and international threats to the financial system, FinCEN 

believes that 90 percent is indicative of satisfactory level of success. 

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

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

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

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

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

or, provided information for an investigative or examination report. In FY 2019, FinCEN 

surpassed its target of 86 percent with 92 percent asserting that queried BSA data led to the 

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

FinCEN Portal and Query training efforts. FinCEN will continue to increase its training efforts 

to provide the FinCEN Portal and FinCEN Query user community with the information they 

need to successfully enhance their investigative efforts. In FY 2020, the target is set at 88 

percent and in FY 2021 at 89 percent. 

Finally, 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. FinCEN collects and 

maintains BSA reports filed by financial institutions and other filers. In turn, FinCEN provides 
FinCEN – 13 

authorized users (including Treasury and TFI) access to a query system containing 14 years of 

BSA data. FinCEN also provides foreign FIUs in the Egmont Group with a secure system for 

exchanging financial intelligence to combat money laundering and terrorist financing. This 

measure is meaningful because the information sharing system allows authorized persons to 

more readily access BSA information and better enable them to conduct investigations more 

efficiently and effectively. In FY 2019, FinCEN exceeded its target of 84 percent with 89 

percent of the users satisfied with the information sharing systems. FinCEN attributes this 

performance to the increased satisfaction with the value of BSA information in FinCEN Query, 

as well as improved system stability. FinCEN is currently undergoing a technical refresh of the 

FinCEN Portal and FinCEN Query applications, which will be implemented in mid FY 2020. As 

such, FinCEN will keep the target at 84 percent due to the learning curve associated with these 

changes. FinCEN expects the target to slightly increase to 85 percent in FY 2021. 

C – Changes in Performance Measures 

FinCEN has no changes in performance measures. 

D – Evidence-Building Activity 

The BSA Value Project will provide FinCEN with a methodology and initial calculation of the 

value of BSA reporting. The Project information and final results will (1) inform and help 

measure the potential impact of proposed regulatory reform actions, including regulatory or 

compliance changes; (2) establish a greater public understanding of how BSA reporting is used; 

(3) support the development of more targeted feedback to financial institutions on the use and 

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

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

identify actions that can enhance the underlying value and use of BSA reporting. The Project 

informs internal FinCEN actions/deliberations as well as external stakeholders (law enforcement, 

regulators, and others). The Project specifically informs the work of the Bank Secrecy Act 

Advisory Group on regulatory reform initiatives. 

FinCEN also conducts research for its advisories. The advisory support analysis for the 

Advisory on Traffic of Fentanyl and Other Synthetic Opioids and the Advisory on Public 

Corruption in Venezuela are examples of this research. The research analyzed BSA and other 

data to produce intelligence reporting on illicit opioid trafficking and Venezuelan government 

corruption. The research supported the development of FinCEN Advisories, assisted financial 

institutions in formulating or enhancing AML processes, and supported other agency activities. 

This information assisted financial institutions, Treasury components and law enforcement in 

identifying money laundering typologies, proactively targeting certain geographical areas, 

developing or enforcing economic sanctions against targeted entities and individuals, and 

enhancing FinCEN’s collaboration with senior officials in Treasury, the Department of Justice, 

and the White House National Security Council on national security issues. 
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 20.8 million filings in FY 2019. 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 (2025), is $422.658 million (including FTE) and the FY 

2021 cost is projected at $25.951 million (including FTE). 

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

investments, can be accessed at: 

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