FinCEN Compliance, End to End
Built for US financial institutions and money services businesses regulated under the Bank Secrecy Act — covering the USA PATRIOT Act, the CDD Final Rule, beneficial ownership reporting under the Corporate Transparency Act, and SAR filing through BSA E-Filing.
The US Treasury's Financial Crime Bureau
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the US Department of the Treasury. It administers the Bank Secrecy Act (BSA) and serves as the United States' Financial Intelligence Unit, collecting and analysing financial data to combat money laundering, terrorist financing, and other financial crimes.
The BSA — first enacted in 1970 and substantially expanded by the USA PATRIOT Act in 2001 and the Anti-Money Laundering Act of 2020 — applies to a broad universe of US financial institutions: banks, credit unions, money services businesses, broker-dealers, mutual funds, casinos, futures commission merchants, insurance companies, and registered investment advisers. Crypto-asset firms operating in the US also fall within scope as money services businesses.
FinCEN does not directly examine institutions — that is delegated to functional regulators such as the OCC, FDIC, Federal Reserve, NCUA, SEC, CFTC, and IRS — but it issues binding rules, sets reporting standards, publishes Geographic Targeting Orders, and operates the BSA E-Filing System through which all federally regulated SARs and CTRs are submitted.
A Layered Federal Framework
US AML obligations sit across primary statute, implementing regulations under 31 CFR Chapter X, and FinCEN advisories. One Constellation maps to all of them.
Bank Secrecy Act
The foundational US AML statute — the recordkeeping, reporting, and program requirements for covered financial institutions, including the obligation to file Currency Transaction Reports and Suspicious Activity Reports.
USA PATRIOT Act §326
The Customer Identification Program (CIP) requirements — minimum standards for verifying customer identity at account opening, plus correspondent-banking due diligence under §312 and §313.
CDD Final Rule (2018)
The Customer Due Diligence rule — codifies the four pillars of an AML program and adds the explicit beneficial-ownership identification requirement for legal-entity customers.
Corporate Transparency Act
Beneficial-ownership reporting to FinCEN's BOI registry — a central federal database of beneficial owners that financial institutions can query for CDD purposes (subject to access rules).
Anti-Money Laundering Act 2020
The most significant BSA reform in two decades — expanded whistleblower rewards, new enforcement priorities, and a mandate for FinCEN to publish national AML/CFT priorities every four years.
OFAC Sanctions Programs
Administered separately by the Office of Foreign Assets Control, but inseparable in practice — the SDN list, Sectoral Sanctions, and country-specific programs that every US institution must screen against.
What FinCEN Requires — and How We Address It
The BSA and the CDD Final Rule require every covered institution to operate the four pillars of an AML program — plus a fifth following the 2018 CDD rule. Here is how each maps to the platform.
Customer Identification Program (CIP)
Verify the identity of every customer at account opening using risk-based procedures — covering name, date of birth, address, and identification number for individuals.
Customer Due Diligence & Beneficial Ownership
Identify and verify any individual owning 25% or more of a legal-entity customer, plus a single individual with significant management responsibility.
Risk-Based AML Program (4 Pillars + 5)
Maintain written internal policies, a designated BSA compliance officer, ongoing training, independent testing, and risk-based ongoing CDD as the fifth pillar.
Ongoing Monitoring & Suspicious Activity Detection
Monitor transactions for patterns inconsistent with the customer's known profile. Detect activity meeting the criteria for SAR filing under 31 CFR 1020.320 and equivalent.
OFAC Sanctions Screening
Screen every customer and counterparty against the SDN list, Sectoral Sanctions Identifications, and active country-program lists in real time at onboarding and on every transaction.
SAR & CTR Filing via BSA E-Filing
File Suspicious Activity Reports within 30 days of detection (60 if no suspect identified). File Currency Transaction Reports for cash transactions over $10,000.
Recordkeeping & Travel Rule
Retain all CDD records and SAR documentation for at least five years. Comply with the BSA Travel Rule for funds transfers of $3,000 or more — passing originator and beneficiary information.
FinCEN & OFAC Penalties Are Substantial
Federal AML enforcement combines FinCEN civil money penalties, OFAC settlements, criminal prosecution under the BSA, and individual liability for compliance officers in egregious cases.
What FinCEN-Aligned Compliance Looks Like
Common Questions
FinCEN Compliance, Done Properly
See the BSA workflows, OFAC screening, and BSA E-Filing SAR/CTR export live — with the actual templates and audit evidence your federal examiner will ask for.