AML Regulations in the US: Overview of Bank Secrecy Act
Last Updated on Feb 16, 2026, 2k Views

AML Regulations in the US: Overview of Bank Secrecy Act
🇺🇸 AML Regulations in the US: Overview of the Bank Secrecy Act (BSA)
The foundation of Anti-Money Laundering (AML) regulation in the United States is the Bank Secrecy Act (BSA), enacted in 1970. It is the primary law requiring financial institutions to assist U.S. government agencies in detecting and preventing money laundering and terrorist financing.
1️⃣ What Is the Bank Secrecy Act?
The BSA, sometimes called the Currency and Foreign Transactions Reporting Act, establishes recordkeeping and reporting requirements for financial institutions to help identify suspicious financial activities.
It was significantly strengthened after the 9/11 attacks by the USA PATRIOT Act, which expanded AML compliance obligations.
2️⃣ Who Enforces the BSA?
The BSA is administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Department of the Treasury.
Federal banking regulators that examine institutions for BSA compliance include:
Federal Reserve System (Fed)
Office of the Comptroller of the Currency (OCC)
Federal Deposit Insurance Corporation (FDIC)
3️⃣ Key Requirements Under the BSA
🔎 1. Customer Identification Program (CIP)
Financial institutions must verify the identity of customers opening accounts. This was introduced under the USA PATRIOT Act.
📋 2. Suspicious Activity Reports (SARs)
Institutions must file SARs when they detect suspicious transactions that may involve fraud, money laundering, or terrorist financing.
💵 3. Currency Transaction Reports (CTRs)
A CTR must be filed for cash transactions exceeding $10,000 in a single business day.
📁 4. Recordkeeping Requirements
Banks must maintain records of:
Cash purchases of negotiable instruments
Wire transfers
Foreign bank account relationships
🏢 5. AML Compliance Program
Financial institutions must implement a written AML program that includes:
Internal controls
Independent testing
Designated BSA/AML officer
Ongoing employee training
4️⃣ Institutions Covered Under the BSA
The BSA applies to more than just banks. Covered entities include:
Banks and credit unions
Money Services Businesses (MSBs)
Broker-dealers
Casinos
Virtual currency businesses
5️⃣ Penalties for Non-Compliance
Violations of the BSA can result in:
Civil monetary penalties (millions to billions of dollars)
Criminal penalties (fines and imprisonment)
Regulatory enforcement actions
Reputational damage
Major enforcement actions have been taken against global banks for AML failures.
6️⃣ Why the BSA Matters
The Bank Secrecy Act is the backbone of the U.S. AML framework. It enables authorities to:
Detect illicit financial flows
Combat drug trafficking and organized crime
Prevent terrorist financing
Enhance financial transparency
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