Financial data is at the heart of solving financial crimes.
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When it comes to financial crimes investigated by IRS Criminal Investigation (IRS-CI), the agency’s most effective tool may not be what you think. It’s data—specifically Bank Secrecy Act (BSA) data.
About the BSA
The Bank Secrecy Act was enacted in 1970 amid growing concern that organized crime, tax evaders and others were moving large sums of money through banks – often offshore – without leaving a useful trail of investigation. The statute required financial institutions to keep certain records and report large cash transactions, establishing the $10,000 reporting limit for currency transactions that remains in place today.
The BSA was greatly expanded in the 1980s through anti-money laundering reforms (primarily in response to the war on drugs) and again after 9/11 with the USA PATRIOT Act. Today, the BSA is administered by the Financial Crimes Enforcement Network (FinCEN)—a name you may recognize if you file an FBAR. The BSA requires financial institutions to file reports, implement compliance programs and conduct customer due diligence, creating a national financial information system that makes illegal money visible and traceable.
CI and BSA data
“BSA data is often the first signal that something is wrong.” explains CI Director Guy Ficco. “These filings become essential puzzle pieces for spotting patterns, tracking financial trails, and building cases that protect taxpayers.”
In fiscal year (FY) 2025, 94% of CI cases were investigated against BSA data, resulting in more than 3.9 million BSA record searches. These deposits are used to build criminal cases against fraudsters involved in money laundering, cybercrimes, misuse of government programs, drug trafficking and other crimes.
This reflects the way modern financial crime investigations are conducted. Financial crime is rarely uncovered through dramatic whistleblowers or surprise discoveries, but through pattern recognition. Suspicious activity reports (SARs), currency transaction reports (CTRs), and 8300 forms provide the structured data that allows investigators to identify and link these patterns.
Types of Reports
What kind of information does CI get from these reports? FinCEN’s annual overview shows that approximately 432,000 registered filers participated in BSA reports in 2024. The actual number of filings is in the tens of millions in SARs and CTRs.
Suspicious activity reports (SARs) are submitted by banks, credit unions, brokers, financial services firms, casinos and other financial institutions subject to the BSA when they identify transactions that may involve violations of the law or attempts to avoid reporting requirements. A SAR must generally be filed within 30 calendar days of the initial detection of events that may constitute suspicious activity, or within 60 days if no suspect is identified. The report includes identifying information about the subject, account information, transaction information, dollar amounts, dates, and a narrative description of the suspicious behavior. FinCEN received approximately 4.7 million SARs in 2024, an average of approximately 12,870 applications per day.
Forex transaction reports (CTRs) are submitted by financial institutions when an individual makes a single cash transaction that exceeds $10,000 in a business day or multiple cash transactions totaling more than $10,000 in a business day. The report must be submitted within 15 calendar days of the transaction. It includes the person’s identifying information, the amount and type of transaction (such as a deposit, withdrawal, or exchange), account numbers, the date of the transaction, and information about the financial institution. In fiscal year 2024, financial institutions submitted approximately 20.5 million CTRs, an average of approximately 56,160 applications per day.
Any person engaged in a trade or business that receives more than $10,000 in cash in one transaction or in two or more related transactions during that trade or business must file Form 8300. The form must be filed within 15 days of receiving the cash. It lists the name, address, tax identification number of the payer, the amount and date of cash received, the nature of the transaction and information about the business submitting the form. The business must also provide a written statement to the payer by January 31 of the following year informing them that the information was reported. In fiscal year 2024, businesses filed about 470,400 Forms 8300 reporting cash payments of more than $10,000.
All such reports are filed electronically with FinCEN and stored in FinCEN’s BSA database.
Is $10,000 too low?
The $10,000 limit remains up for debate. Adjusted for inflation since 1970, the limit would be over $85,000 today.
However, law enforcement generally maintains that the limit remains operationally effective. Take CTRs, for example. Most CTR investigation amounts are between $12,000 and $12,543, and nearly half of the related investigations involve amounts below $20,000, which law enforcement suggests is the effective threshold. This is especially true when you’re looking at references that suggest structure.
Structuring occurs when transactions are broken into smaller amounts to avoid reporting requirements that are triggered at $10,000. Often charged in money laundering cases. For example, instead of depositing $100,000 at once, a person can make a series of smaller deposits on different days or accounts. People who make these deposits are sometimes referred to as “runners” or “smurfs” (which is why you may also see it referred to as a smurf). The structure itself is illegal when the trades are made to avoid reporting requirements — it’s not just illegal to deposit less than $10,000.
“Criminals deliberately structure transactions linked to illegal activity to avoid detection,” Ficco said. “CTRs provide specific transaction data that often serves as evidence when it is proven that criminal activity took place.”
How does data help law enforcement, including CI?
From FY23 to FY25, CI investigated 1,394 cases of refund fraud, with $2.9 billion in alleged fraud. Most of these cases (93%) had a BSA filing related to the main subject. In these cases, financial movements—rapid deposits of government funds, funnel accounts, and high-speed withdrawals—often triggered SAR and CTR activity. The resulting report helped law enforcement piece together these behaviors and see larger patterns.
During the same period, CI opened 1,006 cases of employment tax evasion, with an alleged fraud of $1.4 billion. Almost two-thirds (63%) of these searches had a BSA filing related to the main subject.
BSA data also supports prosecutions that result in high conviction rates, long prison sentences and victim rehabilitation. From FY23 to FY25, CI cases using BSA filings had a conviction rate of 98%. The average prison sentence was 42 months, asset forfeitures exceeded $450 million, and restitution for crime victims totaled nearly $500 million. When law enforcement needs evidence to prosecute these crimes, BSA-related data proves to be very useful.
Working Together
CI is not the only federal agency using BSA data. The Federal Bureau of Investigation (FBI) and Homeland Security Investigations (HSI) also rely on SARs and CTRs to develop leads and support cases. The FBI reported that in fiscal year 2024, 32% of active sophisticated financial crime investigations were associated with SARs and CTRs.
And CI is not acting alone. He leads or participates in SAR review teams in 94 federal judicial districts. These teams, comprised of multiple law enforcement partners, regularly analyze BSA filings to identify triggerable SARs, CTRs, and Forms 8300s and assign leads to the appropriate agencies. Between FY23 and FY25, these groups seized assets worth $385.4 million.
In March 2025, CI announced CI-FIRST (Feedback in Response to Strategic Threats), a public-private partnership to modernize CI’s work with financial institutions. The program provides strategic, non-specific feedback on how BSA filings—especially SARs—are used in tax and financial crime investigations. Includes structured forums and FinTAX crime alerts and tips highlighting emerging tax fraud schemes and benchmarks. The aim is to improve the quality of reporting and align the monitoring of financial institutions with CI’s research priorities.
Similarly, the Optimizing Financial Records Requests (OFRR) initiative aims to streamline how CI issues legal process—such as subpoenas, subpoenas and other financial records requests—and how financial institutions respond. The initiative seeks to standardize request formats, clarify scope and production expectations, and reduce delays in obtaining financial records. By improving consistency and communication between CIs and financial institutions, OFRR is intended to shorten investigation timelines and make financial data collection more efficient.
IRS-CI
CI, the sixth largest federal law enforcement agency, is the criminal investigative arm of the IRS, responsible for investigating economic crimes such as tax fraud, drug trafficking, money laundering, public corruption, health care fraud, and identity theft. While other federal agencies have investigative jurisdiction over money laundering and certain violations of the BSA, the IRS is the only federal agency with investigative jurisdiction over criminal violations of the Internal Revenue Code.
The agency has 18 field offices located throughout the United States and maintains an international presence through overseas attaché positions.
