FINCEN Year in Review 2024 (TL;DR)

FinCEN FY24 Year in Review – Key Takeaways

• BSA Data = Major Law Enforcement Tool

  • IRS-CI, FBI, and HSI rely heavily on SARs/CTRs to start and advance investigations.

  • Example: HSI ran ~290,000 BSA queries, leading to 27k+ new cases, $1.2B seized, and 9k+ convictions.

• FBI Use of BSA Reports

  • Complex financial crime: 32% of active cases tied to SARs/CTRs.

  • Organized crime drug cases: 40% linked.

  • Public corruption, terrorism, and transnational organized crime also strongly tied.

• Reporting Volumes (FY24)

  • SARs: 4.7M filed (~12,870/day).

  • CTRs: 20.5M filed (~56,160/day).

  • FBARs: 1.7M.

  • Form 8300s (cash over $10k in trades/businesses): 470k.

• 314(a) & 314(b) Programs

  • 6,100+ FIs registered for 314(b) info sharing.

  • 48k+ SARs referenced 314(b).

  • 62 terrorism-related SARs cited 314(b).

• Access & Training

  • 432 agencies and 12,000+ users have BSA database access.

  • Over 2.3M BSA searches conducted.

  • 20,600 users trained, 494 programs offered.

• Advisories & Trends (FY24 focus)

  • Counter financing Hamas, Iran-backed terror, fentanyl.

  • ERC fraud, counterfeit passport cards, mail-theft check fraud, elder exploitation, online CVC & child exploitation.

• Public-Private Partnerships

  • 14 FinCEN Exchange events with banks & law enforcement.

  • Rapid Response Program helped claw back funds from cyber-enabled crimes (e.g., BEC).

  • Egmont FIU network: 972 foreign requests in, 452 out, 1,028 incoming spontaneous disclosures.

• Special Measures & Enforcement

  • Section 311/9714 actions against crypto mixers, Al-Huda Bank, and Russian-linked banks.

  • Record penalty: $3.4B against Binance (largest in Treasury history).

  • FY24 civil money penalties: $3.4B across 2 cases; 127 whistleblower tips reviewed.

The full document can be found on the FINCEN website here.