Senate Republicans Introduce Bank Secrecy Act Reform Bill
Commentary by Thomas Delaney
Senate Banking Committee Chair Tim Scott and Senator John Kennedy introduced legislation to raise reporting thresholds for currency transaction reports ("CTRs") and suspicious activity reports ("SARs") under the Bank Secrecy Act ("BSA").
The "Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act" ("STREAMLINE Act") would modernize the BSA by raising financial reporting thresholds and establishing automatic inflation adjustments. The bill directs the Secretary of the Treasury to increase the reporting threshold for CTRs from $10,000 to $30,000 within 180 days of enactment. The new threshold would also apply to reports of coins and currency received in nonfinancial trades or businesses, aligning reporting standards across sectors. Treasury would then be required to adjust the CTR threshold every five years based on changes in the Consumer Price Index, rounded to the nearest $1,000.
To further streamline compliance, the legislation would update SAR filing requirements, raising existing thresholds from $2,000 to $3,000 and from $5,000 to $10,000, depending on transaction type. The bill also directs Treasury to review and modernize reporting and recordkeeping processes to improve efficiency, automate reporting systems, and better target illicit financial activity. Treasury must submit its findings and recommendations to Congress within 360 days. The bill also preserves the Treasury Secretary’s authority to issue or amend Geographic Targeting Orders and to lower reporting thresholds when necessary.
In a statement on the bill, Chair Scott emphasized that the STREAMLINE Act would relieve banks and credit unions of outdated and burdensome reporting requirements. He noted that the legislation modernizes the BSA to focus enforcement on genuine financial crimes rather than creating unnecessary obstacles for everyday Americans.
Commentary
For years, there has been recognition, among financial institutions and segments of the law enforcement community, that raising BSA reporting thresholds, along with other possible changes, could reduce burden without compromising the evidentiary and enforcement objectives of the BSA. The Senate bill is an important and overdue step in furthering that discussion.