Financial Crime World

Strengthening the Bank Secrecy Act (BSA) Framework

The Bank Secrecy Act (BSA) plays a crucial role in combating illicit finance and ensuring the integrity of the financial system. However, there are opportunities to improve the BSA framework to better address emerging threats and opportunities.

Recommendations for Improvement

Enhance Interagency Coordination and Cooperation

  • Strengthen collaboration and coordination: Enhance interagency coordination and cooperation between financial regulatory agencies, law enforcement, and intelligence organizations to ensure a more effective response to illicit finance threats.
  • Improve risk assessments and monitoring: Update and expand the National Terrorist Financing and Money Laundering Risk Assessments to include emerging risks and threats, and regularly review and revise these assessments to reflect changing landscape.

Promote Technology-Enhanced Solutions

  • Leverage emerging technologies: Leverage emerging technologies, such as RegTech and FinTech, to enhance anti-money laundering (AML) and combating the financing of terrorism (CFT) efforts, improve data analysis, and reduce reporting burdens on financial institutions.
  • Enhance information sharing and guidance: Develop clear guidelines and procedures for sharing financial intelligence and threat information among agencies, as well as with international partners, to facilitate more effective decision-making and action.

Increase Transparency and Accountability

  • Provide detailed information: Provide more detailed information on illicit finance-related funding allocations and performance metrics to Congress and the public, allowing for better oversight and evaluation of progress.
  • Streamline reporting requirements: Reduce reporting burdens on financial institutions by streamlining and simplifying reporting requirements while maintaining necessary oversight and regulatory standards.

Additional Suggestions

  • Regularly review the BSA framework: Conduct regular reviews of the BSA framework to assess its effectiveness in addressing emerging threats and opportunities, and make necessary adjustments to ensure it remains relevant and effective.
  • Foster public-private partnerships: Collaborate with the private sector, industry experts, and civil society organizations to leverage their expertise and resources in combating illicit finance.

Specific Areas for Improvement

Better Integration with International Efforts

  • Enhance coordination with international partners: Enhance coordination with international partners to share best practices, align regulatory approaches, and address global illicit finance threats more effectively.

More Effective Use of Financial Intelligence

  • Improve the collection and analysis of financial intelligence: Improve the collection, analysis, and dissemination of financial intelligence to support law enforcement investigations and inform policy decisions.

Enhancing Cybersecurity

  • Implement robust cybersecurity measures: Implement robust cybersecurity measures to protect sensitive financial information and prevent cyber-enabled illicit finance activities.