The Bank Secrecy Act 102: Reporting Requirements

Step Type: Text

What learners will learn: Overview of CTR requirements, exemptions, and history.

Step Description:
This step provides an overview of Currency Transaction Reports (CTRs), including their purpose, reporting requirements, exemptions, and relationship to suspicious activity reporting. Learners will also understand how attempted evasion of CTR filing, known as structuring, is identified and handled within compliance frameworks.

Summary of Content:
Learners will examine the CTR’s role in anti-money laundering (AML) efforts, focusing on its origin under the Bank Secrecy Act, its current electronic filing process (FinCEN Form 112), and the $10,000 cash transaction reporting threshold. The step clarifies that CTRs must be filed regardless of whether the amount is transacted in one or multiple cash transactions in a single business day. It explains that certain groups—such as U.S. banks, government entities, and major publicly traded corporations—may qualify as "exempt persons" from CTR filing requirements. Learners are also introduced to historical shifts in AML reporting, including the transition from suspicious CTR checkboxes to the formalized Suspicious Activity Report (SAR) process in 1996. The step emphasizes how structuring—deliberately altering transactions to avoid CTR filing—is a federal offense. Practical guidance is included on how frontline staff should respond to attempted structuring.

Key Topics Covered:

Step Type: MultiChoice

What learners will learn: Identify requirements, exemptions, and thresholds for CTRs.

Step Description:
This step reinforces knowledge of CTR requirements through active recall. Learners will apply their understanding of when a CTR is required, what exceptions exist, and how banking systems support compliance.

Summary of Content:
Using real-world-style questions, learners explore exemption categories, software behavior, legal obligations around customer communication, the definition of “cash transactions,” structuring red flags, and thresholds for reporting.

Key Topics Covered:

Step Type: Text

What learners will learn: Understand the purpose and reporting obligations of SARs.

Step Description:
This step introduces Suspicious Activity Reports (SARs), including their purpose, filing requirements, timing, and legal protections. Learners will understand how to recognize red flags and ensure their institution meets its obligations under the Bank Secrecy Act (BSA).

Summary of Content:
Learners will explore the origins and role of SARs as a critical component of anti-money laundering (AML) compliance. Introduced in 1996 and mandated under the BSA, SARs are filed when account activity appears suspicious or deviates from a customer’s normal behavior. The step outlines key filing triggers such as attempts to evade reporting thresholds, suspected money laundering, fraud, insider trading, hacking, and unlicensed money service operations. SARs must be filed within 30 days of detecting suspicious activity (with an optional 30-day extension if more evidence is needed), and financial institutions are legally prohibited from disclosing SAR filings to customers. The USA PATRIOT Act expanded SAR obligations to support national security efforts. This step also reinforces the importance of SARs in enabling law enforcement to identify trends in financial crime before they escalate.

Key Topics Covered:

Step Type: Streak

What learners will learn: Key requirements for SARs and FinCEN submissions.

Step Description:
This step builds learner confidence in SAR compliance by prompting recall of key requirements. Learners engage with scenarios covering legal timelines, responsible parties, and the SAR’s function in identifying financial crimes.

Summary of Content:
Learners answer a series of questions on topics such as who files SARs, when, and why. They also review penalties for non-compliance and the role of the USA PATRIOT Act in expanding SAR obligations.

Key Topics Covered:

Step Type: Text

What learners will learn: FBAR requirements, deadlines, and recordkeeping standards.

Step Description:
This step explains the Foreign Bank Account Report (FBAR) requirements under the Bank Secrecy Act (BSA), including who must file, what must be reported, exemptions, deadlines, and recordkeeping responsibilities. It is essential for ensuring U.S. persons remain compliant with offshore account reporting laws.

Summary of Content:
Learners will understand the FBAR’s purpose and who is legally obligated to file it—namely, U.S. citizens, residents, and entities with financial interest or signature authority over foreign financial accounts whose total value exceeds $10,000 during the calendar year. The step clarifies what qualifies as a foreign financial account and highlights key exemptions, including certain retirement accounts and accounts owned by government or international organizations. It outlines filing procedures, including the electronic-only filing requirement via FinCEN’s BSA E-Filing System, and explains when paper filing is permitted by exception. FBARs are due annually on April 15, with an automatic extension to October 15. Learners will also review FBAR authorization procedures (via FinCEN Form 114a) and strict recordkeeping obligations, including a five-year retention period.

Key Topics Covered:

Step Type: True or False

What learners will learn: Identify which foreign accounts must be reported under FBAR.

Step Description:
This step supports recall of FBAR regulations by presenting a series of statements about account types, filing requirements, exemptions, and deadlines.

Summary of Content:
Learners confirm understanding of filing thresholds, account ownership, and reportable account types. Misconceptions about filing with taxes and taxable income are clarified.

Key Topics Covered:

Step Type: Text

What learners will learn: Understand requirements for MILs and CMIRs.

Step Description:
This step explains two important Bank Secrecy Act (BSA) reporting and recordkeeping requirements: the Monetary Instrument Log (MIL) and the Currency and Monetary Instrument Report (CMIR). Learners will understand the thresholds, filing obligations, and documentation standards for each.

Summary of Content:
Learners will review the purpose and use of the Monetary Instrument Log (MIL), which tracks cash purchases of certain monetary instruments (e.g., money orders, cashier's checks, traveler’s checks) between $3,000 and $10,000. While MILs are not submitted to FinCEN, they must be retained by the financial institution for at least five years and made available upon regulatory request. The step also covers the Currency and Monetary Instrument Report (CMIR), known as FinCEN Form 105, which is required when individuals or institutions transport more than $10,000 in currency or monetary instruments into or out of the United States. The CMIR filing applies whether the movement is by mail, shipment, or physical transportation and is mandatory for both senders and recipients.

Key Topics Covered:

Step Type: Polygraph

What learners will learn: Differentiate between MIL and CMIR triggers.

Step Description:
This interactive step tests learners on the specific conditions that require filing a MIL or CMIR. Learners practice identifying when each form is needed and what qualifies as a reportable instrument.

Summary of Content:
Learners are challenged to distinguish between monetary instruments, recognize international currency reporting scenarios, and recall the $10,000 reporting threshold.

Key Topics Covered:

Step Type: Crossword

What learners will learn: Reinforce learning across all reporting requirements in BSA 102.

Step Description:
This gamified step encourages active recall of all content covered in the BSA 102 training. Learners complete a crossword using knowledge of FBARs, SARs, CTRs, and other reporting obligations.

Summary of Content:
Hints test knowledge of account types, deadlines, penalties, and terminology. This reinforces familiarity with acronyms, legal timelines, and compliance logic.

Key Topics Covered: