Effortless BSA Filing for Your MSB

BSA filings are mandatory reports submitted by Money Services Businesses (MSBs) under the Bank Secrecy Act (BSA). They are designed to help FinCEN and law enforcement identify patterns of potential money laundering, terrorist financing, tax evasion, and fraud.

These filings, which include Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs), form the backbone of the U.S. financial crime detection system. Accurate and timely filing not only satisfies federal requirements but also helps protect MSBs from regulatory penalties and reputational risk. Regulators and banks alike view filing compliance as a direct reflection of an MSB’s overall risk management strength.

A CTR must be filed for any transaction or series of related transactions involving more than $10,000 in cash in a single business day for the same customer. The rule applies whether the transaction is a single cash exchange or multiple smaller transactions that together exceed the threshold.

The purpose of a CTR is to create transparency around large cash movements and ensure law enforcement can trace the flow of funds through the financial system. MSBs must include complete customer identification, transaction details, and business information to ensure accuracy and avoid filing errors that trigger regulatory scrutiny.

A SAR is required when an MSB suspects or has reason to believe a transaction involves funds from illegal activity, is designed to evade reporting requirements, or lacks an apparent lawful purpose. The minimum dollar threshold for SARs is typically $2,000. However an SAR must be filed for any known or suspected insider abuse.

Common triggers include customers structuring transactions to stay under $10,000, conducting business inconsistent with their stated purpose, or refusing to provide information about the source of funds. Once suspicion is identified, the MSB must document its findings and file the SAR through the BSA E- Filing System within 30 calendar days.

CTRs are based on transaction thresholds, while SARs are based on suspicious behavior. A CTR reports objective facts about a large cash transaction, while a SAR reports subjective concerns about activity that may be criminal or deceptive.

Both reports serve different but complementary purposes. CTRs show transparency of high-value transactions, while SARs alert regulators to potentially illicit behavior. Together, they help law enforcement build financial intelligence profiles that uncover broader criminal activity.

All MSBs registered with FinCEN; including check cashers, money transmitters, currency exchangers, and issuers/sellers of money orders or traveler’s checks, must file BSA reports when transaction activity meets the applicable criteria.

Failure to file required reports can result in significant civil penalties, criminal exposure, and state licensing issues. Regulators expect every MSB to demonstrate a consistent and well-documented process for identifying, reviewing, and filing reportable activity.

MSBs are required to register with FinCEN using Form 107 within 180 days of beginning operations. The registration must be submitted electronically through the BSA E-Filing System and renewed every two years. (The MSB’s initial registration is good for the remainder of the current year and all the following calendar year. All MSB registrations expire on December 31 st of the 2 nd year of registration.)

The registration process links the business to federal oversight and provides transparency to regulators and financial institutions. Inaccurate or incomplete registration information is one of the most common findings during examinations, often indicating broader compliance weaknesses.

MSBs must keep copies of CTRs, SARs, FinCEN registration confirmations, and all supporting documentation for at least five years from the date of filing. These records must be easily retrievable in case of audit or law enforcement inquiry.

Maintaining proper retention practices is critical. Examiners often test not only whether filings exist but whether the supporting records (customer IDs, transaction evidence, investigation notes) are accessible and complete.

Agencies such as FinCEN, the IRS, and the FBI use CTR and SAR data to trace illicit financial flows, identify organized criminal networks, and uncover emerging money laundering typologies.

Regulators also analyze aggregate BSA data to detect high-risk regions and industries. Consistent and accurate filings from MSBs help demonstrate that the industry is self-monitoring and contributing meaningfully to national financial integrity efforts.

ComplyCheck reviews daily transactions to identify potential CTR and SAR obligations before deadlines are missed. Our system uses automated checks to highlight reportable transactions while compliance specialists verify data for accuracy and completeness. Our highly trained compliance staff will file the required reports with FinCEN within the required timelines.

Each filing is stored securely and linked to customer records, creating a full audit trail for regulators. ComplyCheck’s reporting dashboards also allow MSBs to track trends, recurring customers, and filing patterns, helping clients proactively manage risk rather than react to it.

ComplyCheck maintains a registration calendar that alerts clients well in advance of upcoming renewal deadlines. Our compliance team verifies that all registration information aligns with your AML program, state licensing, and business activity.

We also perform periodic reviews of FinCEN registration data to confirm accuracy, preventing discrepancies that could raise red flags during examinations or when opening or renewing bank accounts.