Banking Associations Push for Updates to BSA Thresholds

The American Bankers Association and state bankers associations from all 50 states urged congressional leaders to advance two bipartisan bills that would increase Bank Secrecy Act ("BSA") reporting thresholds.

In their letter, the associations voiced strong support for the STREAMLINE Act and the Financial Reporting Threshold Modernization Act. The bills would raise the Currency Transaction Report threshold from $10,000 to $30,000 and index it to inflation every five years and increase certain Suspicious Activity Report ("SAR") thresholds from $5,000 to $10,000. The associations noted that these thresholds have not been updated in decades, and argued that the low thresholds resulted in excessive reporting that strains bank resources without improving law-enforcement utility. They argued that increasing the thresholds would allow banks to better focus on higher-risk illicit finance threats such as terrorism, drug trafficking, fraud, and scams.

The associations also urged Congress, Treasury, and federal banking agencies to pursue broader BSA modernization. They called for additional reforms, including: (i) revising BSA program rules to support risk-based resource allocation; (ii) updating SAR rules and forms to prioritize high-risk suspicious activity and curb defensive filings; (iii) reforming FinCEN’s 2016 Customer Due Diligence rule to collect information at the customer level rather than for each new account; and (iv) applying equivalent BSA obligations to nonbank financial institutions to ensure consistent protection of the financial system.