📘 Resource: Background and History of the BSA
Step Type: Text
What learners will learn: Overview of requirements and history of the BSA.
Step Description:
This step provides a foundational understanding of the Bank Secrecy Act (BSA), including its purpose, legal requirements, and historical development. It also introduces learners to the regulatory authority responsible for enforcing BSA compliance across financial institutions in the U.S.
Summary of Content:
Learners will explore the origins and objectives of the BSA, first enacted in 1970 to detect and deter money laundering and related financial crimes. The step explains the BSA’s core requirements, including mandatory recordkeeping, cash transaction reporting, and the filing of suspicious activity reports (SARs). It also traces the BSA’s legal evolution, from early constitutional challenges through significant amendments like the USA PATRIOT Act, which expanded obligations for financial institutions by mandating AML programs, employee training, independent audits, and designated compliance officers. Learners will also review an unsuccessful attempt to amend the Act further via the 2018 Illicit Arts and Antiquities Trafficking Prevention Act (IAATP). Finally, the step clarifies FinCEN’s delegated authority to implement and enforce BSA regulations.
Key Topics Covered:
Purpose and scope of the Bank Secrecy Act
Recordkeeping and reporting thresholds (e.g., cash transactions >$10,000)
Suspicious Activity Reports (SARs) and their role in detecting financial crime
Historical legal challenges to the BSA and constitutional rulings
Major amendments, including the USA PATRIOT Act
Core AML program requirements: internal controls, training, audits, compliance officers
FinCEN’s role in administering and enforcing BSA regulations
Legislative attempts to expand the BSA (e.g., IAATP and its rejection)
📘 Background of the BSA
Step Type: MultiChoice
What learners will learn: Basic requirements of financial institutions under the BSA.
Step Description:
This step breaks down the key responsibilities financial institutions have under the BSA, as well as the government bodies responsible for regulation and enforcement.
Summary of Content:
Learners review key reporting requirements, including SARs, AML program mandates, and compliance designations. Also covered are the BSA’s regulatory structure, including FinCEN and the Secretary of the Treasury.
Key Topics Covered:
Core BSA compliance obligations for financial institutions
Reporting thresholds and required programs
Which activities and crimes must be reported under BSA
The agencies responsible for regulation and enforcement
📘 The BSA’s History
Step Type: Streak
What learners will learn: History of the BSA.
Step Description:
Explore the legislative and legal history of the Bank Secrecy Act, including major milestones and Supreme Court rulings.
Summary of Content:
Covers the BSA’s origin in 1970, Richard Nixon’s role in signing it into law, and key legal events such as California Bankers Assn. v. Shultz. Also addresses the PATRIOT Act’s expansion and when institutions began complying.
Key Topics Covered:
Year and president behind the original BSA legislation
Supreme Court ruling affirming the BSA’s constitutionality
Expansion of the BSA under the USA PATRIOT Act
When financial institutions began actively complying
📘 Resource: FinCEN
Step Type: Text
What learners will learn: FinCEN scope and purpose.
Step Description:
This step introduces FinCEN (the Financial Crimes Enforcement Network), the U.S. government’s financial intelligence unit. Learners will explore FinCEN’s mission, core responsibilities, and international role in safeguarding the financial system through the enforcement and oversight of Bank Secrecy Act (BSA) regulations.
Summary of Content:
Learners will gain a clear understanding of FinCEN’s role within the U.S. Department of the Treasury, including its mission to combat money laundering, terrorist financing, and other illicit financial activities. The step outlines how FinCEN receives and analyzes financial transaction data, issues and enforces BSA regulations, and supports law enforcement and policy efforts at every level of government. It explains how FinCEN functions as the United States’ Financial Intelligence Unit (FIU), collaborating globally through the Egmont Group to share intelligence and disrupt financial crime networks. The foundational concept behind FinCEN’s work—“follow the money”—is highlighted, showing how financial trails are used to detect and prosecute a wide range of criminal activity, from fraud and tax evasion to terrorism financing.
Key Topics Covered:
FinCEN’s mission and placement within the U.S. Department of the Treasury
FinCEN’s regulatory authority under the BSA and USA PATRIOT Act
Core responsibilities: data collection, analysis, dissemination, and regulatory enforcement
FinCEN’s support for law enforcement, policymakers, and the financial industry
The concept of “follow the money” in financial investigations
FinCEN’s role as the U.S. Financial Intelligence Unit (FIU)
Participation in the Egmont Group and global AML/CFT cooperation
How FinCEN data is used in detecting and prosecuting financial crimes
📘 FinCEN's Scope and Mission
Step Type: Polygraph
What learners will learn: FinCEN’s scope and mission review.
Step Description:
Test your knowledge of FinCEN’s function, mission, and role under the BSA.
Summary of Content:
Explores FinCEN’s authority, legislative basis (e.g., BSA and PATRIOT Act), and global coordination responsibilities. Reinforces its role in collecting, analyzing, and sharing financial intelligence.
Key Topics Covered:
FinCEN’s legal framework and appointment
Its mission to combat financial crime and promote security
FinCEN’s international partnerships and intelligence sharing
📘 FinCEN’s Duties
Step Type: Streak
What learners will learn: FinCEN’s primary duties.
Step Description:
Cover the primary responsibilities of FinCEN in this step, such as enforcing regulations, data collection/analysis, and supporting compliance and investigations to combat financial crimes.
Summary of Content:
Highlights FinCEN’s operational responsibilities: issuing guidance, supporting compliance, analyzing data, and helping law enforcement. Learners examine how FinCEN manages AML data and coordinates across sectors and borders.
Key Topics Covered:
FinCEN’s regulatory and enforcement functions
How it supports institutions and law enforcement
Its use of data to guide compliance and investigation efforts
📘 FinCEN’s Role as an FIU
Step Type: True or False
What learners will learn: Duties of FinCEN as an FIU.
Step Description:
Financial Intelligence Units (FIUs) serve a common goal of disrupting financial crimes through an internationally-shared information network. This step focuses on FinCEN’s role as an FIU.
Summary of Content:
Covers FinCEN’s role in the global FIU network, its partnerships, and its support of law enforcement through intelligence analysis. Learners explore how FIUs work together to follow money trails and fight financial crimes.
Key Topics Covered:
FinCEN’s designation as the U.S. FIU
Collaboration with over 100 global FIUs
How FinCEN uses intelligence to combat terrorism and fraud
📘 Mastery Test: Bank Secrecy Act 101
Step Type: Crossword
What learners will learn: Bank Secrecy Act 101 course review.
Step Description:
Test your knowledge on Bank Secrecy Act 101 with this mastery step!
Summary of Content:
This crossword reinforces key concepts from the BSA 101 course, including terminology, legislation, enforcement bodies, and the evolution of anti-money laundering policy.
Key Topics Covered:
Common AML and BSA-related terminology
Reporting obligations and enforcement authorities
The impact of the USA PATRIOT Act on BSA rules
FinCEN’s role in AML enforcement and intelligence