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What Are BSA Filings?
Under the Bank Secrecy Act, financial institutions and certain businesses report specific financial activity to federal authorities to help detect and prevent money laundering and other financial crimes. Common filings include:
Suspicious Activity Reports (SARs) – alerts about potentially suspicious or unusual financial behavior.
Currency Transaction Reports (CTRs) – reports of cash transactions over $10,000.
Form 8300 – filed by businesses when they receive cash over $10,000.
These reports aren’t just compliance obligations for banks — they are critical investigative tools for law enforcement, including IRS-CI.
BSA Data in Nearly Every IRS-CI Investigation
100% Special Depreciation Allowance Eligibility
According to the latest IRS-CI release:
📊 94% of all Criminal Investigation cases were searched against BSA data in Fiscal Year 2025 — more than 3.9 million searches.
📊 Nearly 89% of investigations had a BSA filing linked to the primary subject.
📊 More than 80% of these cases involved SARs, and over 65% had CTR data tied to subjects.
📊 Around 12% of cases were initiated directly from a BSA filing.
This means that BSA data plays a role in almost every financial crime investigation IRS-CI conducts — from tax evasion and refund fraud to money laundering and narcotics trafficking.
Why This Matters to Tax Preparers
Tax preparers are not just compliance partners — you are also often the first professionals to help clients understand complex financial reporting responsibilities. The rise in enforcement tied to BSA data has several implications:
- Increased Scrutiny on Complex Financial Behavior
Many investigations that lead to prosecution involved subjects whose financial activity triggered BSA filings — whether legitimately flagged by a bank or uncovered through law enforcement analysis. Complex client activity including unusual cash transactions, structured deposits/withdrawals, or inconsistent reporting may prompt further scrutiny.
- Interconnected With Tax-Related Investigations
In the last reporting period, IRS-CI used BSA data to investigate refund fraud and employment tax evasion cases significant in value — with nearly every fraud case having a BSA filing associated with the subject.
- Convictions and Enforcement Outcomes
Cases linked to BSA data continue to produce strong prosecutorial results — with high conviction rates and meaningful sentences — underscoring how financial data evidence supports successful outcomes for the government.
Practical Takeaways for Tax Preparers
- Understand financial reporting requirements clearly: Educate clients on when and how SARs, CTRs, and other filings like Form 8300 may be triggered by their behavior — whether they are businesses, high net worth individuals, or cash-intensive operations.
- Spot red flags early: Unusual patterns such as frequent large cash deposits just below reporting thresholds, mismatched income and expenses, or inconsistent documentation can not only trigger BSA filings at banks but also Flag IRS attention.
- Document everything: Good recordkeeping and thorough explanations for financial transactions help clients and reduce risk — particularly if financial institutions file reports that may later intersect with IRS-CI inquiries.
- Stay current with IRS trends: IRS-CI’s use of BSA data reflects broader enforcement priorities where tax crimes intersect with broader financial investigations. Awareness of these trends helps prepare you and your clients for compliance and risk management.
In Summary
The IRS-CI’s latest metrics confirm that BSA filings are not peripheral — they are foundational to financial crime investigations involving tax and non-tax issues alike. For National Tax Preparers of America members, staying informed about how these data sources are used — and why they matter — enhances your ability to serve clients, identify compliance gaps, and anticipate the investigative implications of financial behaviors.
