IRS-CI: How Bank Secrecy Act Data Fuels Financial Crime Investigations

The IRS’s Criminal Investigation (CI) unit increasingly relies on financial data – specifically, information gathered through Bank Secrecy Act (BSA) filings – to build and win criminal cases. This shift reflects a broader trend in financial crime investigation, moving away from reliance on informants and toward pattern recognition enabled by large datasets. Understanding how this data is collected, analyzed, and used is crucial for businesses and individuals alike, as compliance with BSA regulations is paramount.

The Bank Secrecy Act: A Foundation for Investigation

Enacted in 1970, the Bank Secrecy Act was initially designed to combat organized crime and tax evasion by requiring financial institutions to maintain records and report large cash transactions. The original law established a $10,000 reporting threshold for currency transactions, a figure that remains in place today. As reported by the American Bankers Association, the BSA has been significantly expanded over the decades, particularly in the 1980s with anti-money laundering reforms and again after 9/11 with the USA PATRIOT Act.

Today, the BSA is administered by the Financial Crimes Enforcement Network (FinCEN). Financial institutions are required to file reports, implement compliance programs, and conduct customer due diligence, creating a nationwide financial intelligence system. This system aims to make illicit money movements visible and traceable, providing law enforcement with critical leads.

BSA Data in Action: IRS-CI’s Approach

In fiscal year 2025, a remarkable 94% of IRS-CI cases were searched against BSA data, resulting in over 3.9 million searches of BSA filings. According to the IRS, this underscores the integral role BSA data plays in uncovering and prosecuting financial crimes across the country. IRS-CI Chief Guy Ficco emphasizes that “BSA data is often the first signal that something isn’t right,” and these filings are “essential puzzle pieces” in identifying patterns and building cases.

The types of crimes investigated using BSA data are diverse, ranging from money laundering and cybercrimes to abuse of government programs and narcotics trafficking. From fiscal years 2023-2025, CI investigated 1,394 cases of refund fraud with alleged fraud totaling $2.9 billion, and 99% of these cases had a BSA filing associated with the primary subject. Similarly, 1,006 employment tax evasion cases were opened during the same period, with alleged fraud totaling $1.4 billion, and 63% of these investigations had a BSA filing associated with the primary subject.

Key BSA Reports: SARs, CTRs, and Form 8300

The BSA relies on several key reporting mechanisms. Suspicious Activity Reports (SARs) are filed by financial institutions when they detect transactions that may involve violations of law or attempts to evade reporting requirements. In fiscal year 2024, FinCEN received approximately 4.7 million SARs, averaging roughly 12,870 filings per day.

Currency Transaction Reports (CTRs) are filed when a person conducts a single cash transaction exceeding $10,000 in a business day, or multiple transactions aggregating to more than $10,000. Financial institutions filed about 20.5 million CTRs in FY 2024, averaging approximately 56,160 filings per day.

Finally, Form 8300 is filed by businesses that receive more than $10,000 in cash in a single transaction or related transactions. Approximately 470,400 Forms 8300 were filed in FY 2024, reporting cash payments over $10,000. All of these reports are filed electronically with FinCEN and stored in its BSA database.

The $10,000 Threshold: A Continuing Debate

The $10,000 reporting threshold, originally set in 1970, has been a subject of ongoing debate. Adjusted for inflation, that threshold would now exceed $85,000. Despite calls for an increase, law enforcement generally maintains that the current threshold remains effective. Investigative amounts often cluster between $12,000 and $12,543, suggesting that individuals are attempting to avoid the reporting requirement, a practice known as structuring.

Structuring involves breaking down large transactions into smaller amounts to avoid triggering the $10,000 reporting threshold. This proves illegal when conducted with the intent to evade reporting requirements. As Ficco noted, CTRs provide “concrete transactional data that often serves as evidence when proving criminal activity took place.”

Beyond the IRS: Collaboration and Future Initiatives

The use of BSA data isn’t limited to the IRS-CI. The Federal Bureau of Investigation (FBI) and Homeland Security Investigations (HSI) also rely on SARs and CTRs to develop leads and support their investigations. The FBI reported that 32% of its active complex financial crime investigations were linked to SARs and CTRs in FY 2024.

To enhance collaboration and improve data quality, CI launched CI-FIRST (Feedback in Response to Strategic Threats) in March 2025. This public-private partnership provides financial institutions with feedback on how BSA filings are used in investigations, aiming to improve reporting quality and align monitoring with CI’s priorities. The Optimizing Financial Records Requests (OFRR) initiative seeks to streamline the process of issuing and responding to financial records requests, further improving efficiency.

What’s Next: Strengthening the Financial Intelligence Network

The increasing reliance on BSA data highlights the importance of robust compliance programs for financial institutions. Businesses must prioritize accurate record-keeping, diligent customer due diligence, and timely reporting of suspicious activity. The IRS-CI’s continued focus on leveraging BSA data, coupled with initiatives like CI-FIRST and OFRR, suggests a future where financial crime investigations are even more data-driven and collaborative. As Accounting Today reported, this trend is likely to continue, making BSA compliance a critical component of risk management for businesses of all sizes.