In 1970, Congress passed the Currency and Foreign Transactions Reporting Act, commonly known as the Bank Secrecy Act (BSA), establishing recordkeeping and reporting requirements by private individuals, banks, and other financial institutions. The BSA, along with other anti-money laundering (AML) statutes and regulations, comprise the AML regime that is intended to safeguard the U.S. financial system, and its financial institutions, from financial crimes.
All credit unions must comply with BSA regulations.
12 U.S.C. § 1786(q)(2) requires NCUA to review a credit union’s BSA compliance program during each examination. NCUA plays a critical role in implementing BSA regulations by developing examination guidance and enforcing compliance with the BSA in federally insured credit unions.
Note that the Department of The Treasury and Financial Crimes Enforcement Network (FinCEN) regulations use the term “bank” to define a variety of financial institutions, including credit unions, and the terms “bank” and “credit union” are used interchangeably for ease in drafting joint statements from the federal financial institution regulatory agencies.
BSA / AML Laws & Regulations
- BSA Statutes: 12 U.S.C. § 1829b, 1951-1960; 31 U.S.C. § 5311-5314, 5316-5336
- Codified BSA: 31 CFR Ch. X
- Codified BSA Requirements for Credit Unions: 12 CFR Ch. VII Part 748
- Federal Credit Union Act / NCUA Rules & Regulations
- Money Laundering Statutes: 18 U.S.C. § 1956, 1957, 1960
- USA PATRIOT ACT Sections 311-314, 319(b), 325-326, 351-352, 356, 359, 362
- Anti-Money Laundering Act (AMLA) / Corporate Transparency Act (CTA)
- OFAC Regulations & Reporting Requirements: 31 CFR Ch. V
BSA / AML Policy, Guidance, & Tools
- NCUA Examiner’s Guide: BSA Compliance Section
- NCUA National Supervision Policy Manual (NSPM): BSA Supervision Section
- Federal Financial Institutions Examination Council (FFIEC) BSA/AML Examination Manual
- OFAC: Sanctions Programs / Sanctions List Search / Frequently Asked Questions (FAQ) Interagency Issuances and Joint Statements
- Interagency Statement on Sharing BSA Resources (18-CU-04; October 2018)
- Joint Statement to Encourage Innovative Approaches to BSA/AML Compliance (December 3, 2018)
- Joint Statement on Risk-Focused BSA/AML Supervision (July 22, 2019)
- Joint Statement on Enforcement of BSA/ AML Requirements (August 13, 2020)
- Interagency Issuance of FAQs on SAR and Other AML Requirements (January 21, 2021)
- Interagency Statement on the Issuance of the Anti-Money Laundering/Countering the Financing of Terrorism National Priorities (21-CU-05; June 2021)
- Joint Statement on Risk-Based Approach to Assessing Customer Relationships and Conducting Customer Due Diligence (22-CU-08; July 2022)
- Joint Statement on Issuance of CIP Exemptive Relief Order (June 27, 2025)
- Joint Statement on FAQs Regarding SAR Reporting Requirements (October 9, 2025)
- FinCEN Issues Exceptive Relief to Streamline CDD Requirements (February 17, 2026)
- FinCEN Issues Joint Advisory on Non-Work Authorized Populations and Their Employers and Risks to the Integrity of the U.S. Financial System (June 05, 2026)
- Agencies Issue Guidance on Lending to Individuals Not Legally Authorized to Work in the United States (July 13, 2026)
Financial Crimes Enforcement Network
FinCEN is a bureau within the U.S. Department of the Treasury and is the delegated administrator of the BSA. In this capacity, FinCEN issues regulations and interpretive guidance, provides outreach to regulated industries, supports the examination functions performed by federal financial institution regulatory agencies, and pursues civil enforcement actions when warranted.
- For questions about FinCEN, its policies and programs, or BSA requirements and forms, visit www.fincen.gov/contact to submit an inquiry.
- Financial institutions are required to immediately report suspicious transactions that may relate to terrorist activity, or an ongoing money laundering scheme, to law enforcement or directly to FinCEN by calling 1.866.556.3974 (7 days a week, 24 hours a day), in addition to filing a timely suspicious activity report (SAR), pursuant to 31 CFR §1020.320(b)(3), 12 CFR §748.1(d)(2)(i), and FinCEN SAR Electronic Filing Requirements 9.5(2).
- FinCEN Resources provide additional guidance and information regarding the BSA including (but not limited to):
- Alerts, Advisories, Notices, Bulletins, and Fact Sheets
- BSA Filing Information
- Beneficial Ownership Information Reporting
- Financial Trend Analysis
- Important Information for Financial Institutions
- FinCEN Exchange
- SAR Stats
- FinCEN USA PATRIOT ACT 314(a) / 314(b) Information
- FinCEN Section 314(b) Fact Sheet (June 12, 2026)
- Interagency Statement for Banks on the Issuance of the Beneficial Ownership Information Access Rule (December 21, 2023)
BSA Reporting
Financial institutions are required to electronically file BSA reports in the BSA E-Filing System. For more information, see the Notice on E-Filing Mandate.
The BSA E-Filing system supports either individual or batched electronic filing to the BSA database through a secure FinCEN network. FinCEN also uses the system to issue advisories and system updates to the user community and allows for secure messaging with FinCEN.
For BSA report electronic filing instructions and user guides, see FinCEN’s Filing Information.
To test a batch filing program, visit BSA E-Filing Test System. Do not mail or electronically attempt to file a test report.
Contact NCUA
To ask a BSA related question, send an email to the BSA Policy mailbox at BSAPolicy@NCUA.gov.