On October 21, 2025, Senate Republicans introduced a new bill that would increase the threshold amounts applicable to certain currency transaction reports and suspicious activity reports under the Bank Secrecy Act (BSA). The BSA requires financial institutions to assist the government in detecting and preventing financial crimes. The bill is titled the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, also referred to as the STREAMLINE Act. The bill’s provisions are meant to reflect the changes in the U.S. and global economy and the risks associated with large cash transactions.
The current provisions of the BSA require financial institutions to submit reports to the U.S. Department of the Treasury’s Financial Crimes Enforcement Network (FinCEN) when transactions meet designated monetary thresholds. The transaction thresholds have remained unchanged since they were established in 1970. Financial institutions must file currency transaction reports for cash transactions over $10,000. Additionally, they must submit suspicious activity reports for both cash and non-cash transactions above $2,000 if the financial institution is a money service business (such as a currency exchange), and above $5,000 for depository institutions (such as banks) whenever they know, suspect, or have reason to know or suspect that the transaction involves illegal activity.
The activity reports submitted pursuant to the BSA are integral to other anti-money laundering laws by using an objective criteria for potentially illicit cash transactions, thereby supporting the detection and investigation of criminal conduct.
Given that the BSA threshold requirements have not been modified for over 50 years, the bill proposes increasing the thresholds from $10,000 to $30,000 for currency transaction reports, and from $2,000 to $3,000 and $5,000 to $10,000, for money service businesses and depository institutions, respectively, for suspicious activity reports. Along with these threshold increases, the STREAMLINE Act would impose regular inflation adjustments every five years to certain threshold amounts.
The proposed changes are intended to remove what Senate Republicans believe to be "unnecessary burdens" that the reporting requirements impose on financial institutions and "target true financial crime" instead of "generating excessive paperwork." The STREAMLINE Act has garnered considerable backing from the banking sector and aligns with the Trump administration’s objectives to combat financial crime.
Financial institutions subject to these requirements should closely monitor developments related to the STREAMLINE Act and its potential enactment in order to ensure complete and accurate transaction reporting and avoid running afoul of applicable BSA reporting obligations.
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