A Quick Reference Guide
for Money Services Businesses
The Bank Secrecy Act
The Bank Secrecy Act (BSA) was enacted by Congress in 1970 to fight money laundering and other financial crimes.
The BSA requires many financial institutions to create “paper trails” by keeping records and filing reports on certain transactions. These reports are submitted to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN). FinCEN collects and analyzes the information to support law enforcement investigative efforts and to provide U.S. policy makers with strategic analyses of domestic worldwide money laundering developments, trends and patterns.
The BSA’s reporting and recordkeeping provisions apply to banks, savings and loans, and credit unions as well as other financial institutions, including money services businesses (MSBs).
In addition to the general guidelines provided here, other BSA requirements may apply to a specific MSB. Please visit www.msb.gov for more regulatory information.
For further information, see our pamphlet entitled “Reporting Suspicious Activity: A Quick Reference Guide for Money Services Businesses.”
Currency Transaction Reports
MSBs must file a Currency Transaction Report (CTR) within 15 days whenever a transaction or series of transactions in currency:
Multiple cash transactions are considered to be one transaction on which a CTR must be filed if the MSB has knowledge that:
How to File a CTR
1. Verify and record customer ID.
Cash Purchases of $3,000-$10,000, Inclusive
MSBs that sell money orders or traveler’s checks are required to record cash purchases involving $3,000- $10,000, inclusive.
Multiple cash purchases of monetary instruments totalling $3,000 or more must be treated as one purchase which must be recorded if:
1. They are made at the same time, or
How to record a money order or traveler’s check sale for cash of $3,000-$10,000, inclusive:
1. Verify and record customer information, including ID.
Money Transfers of $3,000 or More
MSBs that provide money transfer services must obtain and record specific information for each money transfer of $3,000 or more, regardless of the method of payment.
How to record a money transfer of $3,000 or more for money transfer senders and receivers:
1. Verify customer ID.
Currency Exchanges of More Than $1,000
Currency exchangers must keep a record of each exchange totaling more than $1,000 in either domestic or foreign currency.
How to record a currency exchange:
1. Record customer information.
Suspicious Activity Reporting Requirements
Certain money services businesses – businesses that provide money transfers or currency dealing or exchange; or businesses that issue, sell, or redeem money orders or traveler’s checks – must report suspicious activity involving any transaction or pattern of transactions at or above a certain amount:
You have 30 calendar days to file a SAR after becoming aware of any suspicious transaction that is required to be reported.
How to Report Suspicious Activity
1. Record relevant information on a Suspicious Activity
Report by MSB (SAR-MSB) form available at
www.msb.gov or by calling the IRS Forms Distribution
Summary of BSA Requirements for MSBs
For answers to your questions about BSA reporting and recordkeeping requirements, please visit www.msb.gov.
Detroit Computing Center Hotline
FinCEN Regulatory Helpline
To order free guidance materials
To order BSA forms from the
This pamphlet is intended only as general guidance on requirements under 31 CFR Part 103. This pamphlet does not replace or supersede the regulation.