Bank Secrecy Act
The foundational U.S. anti-money-laundering statute; requires financial institutions, including money transmitters and, since the GENIUS Act, payment-stablecoin issuers, to maintain AML programs and report suspicious activity to FinCEN.
The Bank Secrecy Act (BSA), enacted in 1970, is the core federal anti-money-laundering (AML) framework. It requires “financial institutions” to keep records and file reports that help detect and prevent money laundering, including customer identification, transaction monitoring, currency transaction reports, and suspicious activity reports. It is administered by the Financial Crimes Enforcement Network (FinCEN), a bureau of the U.S. Treasury.
For fintech, the BSA reaches further than many founders expect. Money services businesses, including money transmitters and many cryptocurrency businesses, are financial institutions subject to BSA registration and to a written, risk-based AML program. The GENIUS Act of 2025 expressly brought payment-stablecoin issuers inside the BSA as financial institutions.
A BSA/AML program is not a policy document filed and forgotten. It requires a designated compliance officer, ongoing training, independent testing, and monitoring proportionate to the institution's risk. For a money-movement product, the BSA program is a launch prerequisite, not a later cleanup.