Bank Secrecy Act and AML

The Bank Secrecy Act is the federal law requiring financial institutions, including registered crypto money services businesses, to maintain anti-money laundering programs, verify customers, keep records, and report suspicious activity and large cash transactions.

FinCEN administers it. The FBAR requirement comes from the same law. Exchanges’ KYC programs and suspicious activity reports exist because of it.

Why it matters: BSA data is how much of the IRS’s information about crypto users originates. See KYC.

Where this comes up in our work

Token and Web3 opinion letters

Howey analysis and written opinions for token projects and exchanges.

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Definitions are general information, not legal advice, and may not reflect the most recent changes in law.