Detailed Information on the
Bank Secrecy Act Data Collection, Retrieval and Sharing Assessment

Increase the quality of BSA data by correcting data quality issues. In FY 2007, FinCEN, in collaboration with IRS, initiated a BSA Data Management framework process to increase the quality of BSA data. This initiative identified issues that affect the quality of BSA data, which were prioritized. FinCEN and IRS have established a process for updating and tracking these issues. In FY 2008, FinCEN and IRS plan to implement a minimum of two releases of system changes to address between 20%-25% of the issues prioritized as of July 2007. FinCEN and IRS will meet quarterly to review their progress toward improving BSA data quality. FinCEN will also evaluate the BSA Information framework process established to measure the overall progress and identify ways to simplify or improve the process.

FinCEN will look at ways to reduce filing burden on the financial community, including streamlining reporting obligations and increasing feedback and notices to filers. Progress will be tracked and reported to stakeholders/published by FinCEN.

FinCEN will work with stakeholders, through a formal partnership established in 2007, to identify additional steps on how to increase efficiency in completing and filing required reports. In order to highlight and track progress, FinCEN will quantify and publish the reduction in filing burden.

FinCEN created a measure and targets to track the number of top 650 filers who file reports electronically. FinCEN will continue to monitor the progress and tracking of this measure and identify where improvements can be made. This will be a critical project as this measure is linked to the long-term E-Filing goals.

FinCEN will survey BSA Direct's users to systematically find out if users are receiving the information they need in a timely manner, if the information they are receiving is helpful, and if there are any problems with the information, format, etc. A survey of BSA E-Filers was completed, and FinCEN began surveying the Secure Outreach and WebCBRS users. FinCEN plans to examine both surveys and determine appropriate improvements.

FinCEN has taken steps to create a performance measure to measure the quality of information provided on Suspicious Activity Reports. In FY 2006, FinCEN established a measure, including a target rate, that tracks the critical field omission rate of E-Filed SARs to measure the quality of information provide on SARs. FinCEN will continue to monitor duplicate SAR data for filers with systemic duplicate filings, implement established referral procedures on all filers with systemic omission rate problems, and monitor future duplicate SAR data to verify referred institutions have corrected their systemic problems.

Measure: Number of users directly accessing BSA data.

Explanation:The number of users who have accessed the BSA data, either through FinCEN's Secure Outreach system or through a bulk distribution of BSA data. FinCEN has begun to provide the BSA dataset to high volume federal users, who can then combine the BSA data with their own internal databases.

Measure: Share of BSA filings submitted electronically

Explanation:The percentage of electronic BSA filings submitted via the web-based system, based on two months of the fiscal year. Using the two most recent months of fiscal year data to calculate the performance is a better indicator since it enables management to look at a recent snapshot of data to analyze any current performance issues in order to make timely performance decisions which may have not been apparent using cumulative year data. Given the difficulty of tracking the ultimate usefulness of the BSA data to law enforcement communities, BSA forms filed electronically is a proxy outcome measure for FinCEN. E-Filing expedites the processing time and in turn helps ensure that the information is available for law enforcement purposes.

Measure: Cost Per BSA Form E-Filed

Explanation:This measure tracks the Government 's reoccuring operations and maintenance costs associated with E-Filing against the number of BSA Forms E-Filed. As more financial institutions E-File, it is anticipated that the cost per BSA Form E-Filed will decrease.

Is the program purpose clear?

Explanation: The program's purpose is to ensure the effective collection, retrieval, and sharing of the highly sensitive and confidential information collected under the Bank Secrecy Act (BSA). The BSA, the Nation's comprehensive anti-money laundering statute, requires certain reporting and recordkeeping requirements by banks and other financial institutions, including reporting suspicious activity reports that could trigger investigations. The PATRIOT Act mandated that FinCEN establish electronic filing, develop an information sharing process, and maintain a database that allows financial institutions to file reports and provide financial institutions with alerts and other information regarding suspicious activities that warrant immediate and enhanced scrutiny.

Evidence: 31 USC, Chapter 53, subchapter II, subsection 5319; PATRIOT Act, Section 361, Subsection 310 (B) and (C); FinCEN Strategic Plan FY 2006-2008, pg. 6; FY 2006 FinCEN Congressional Budget Submission, pg. 3.

Does the program address a specific and existing problem, interest, or need?

Explanation: The BSA data collected and disseminated by FinCEN provides an information foundation to help detect financial crime. The collection of this information is critical to FinCEN's role in counter-terrorism efforts, highlighted and expanded after 9/11 in the USA PATRIOT Act. The need for this program remains strong as the industries covered by BSA regulations grow and more users request and access the data.

Evidence: PATRIOT Act, Section 361, Subsection 310 (B) and (C) ; PATRIOT Act Section 362, (a), (1) and (2); and FinCEN FY 2004 Annual Report, pgs 5-6 and 25; Section 5318 of title 31, USC; 31 CFR, Part 103, Sec. 103.33

Is the program designed so that it is not redundant or duplicative of any other Federal, state, local or private effort?

Explanation: This program is unique through its support of the intelligence and law enforcement communities. The program ensures the efficient and timely collection, maintenance, and dissemination of financial information critical to investigations of illicit finance, not carried out by any other entity. Additionally, to avoid duplication of law enforcement investigations, FinCEN networks those persons who are querying the data to help prevent overlapping of law enforcement resources.

Evidence: 31 USC 5319, Chapter 53, subchapter II, subsection 5319; PATRIOT Act, Section 361, Subsection 310 (B) and (C); FY 2006 Congressional Budget Submission, pg 3.

Is the program design free of major flaws that would limit the program's effectiveness or efficiency?

Explanation: Currently limitations exist because a portion of the collection and retrieval process is housed and managed at the Internal Revenue Service's Detroit Computing Center. However, a major focus of this program is the modernization of the current processes to bring the program's three activities under one FinCEN-managed system - BSA Direct - by October 2005. For the components now under FinCEN's control, there has been a continued increase in efficiency in electronic data collection and direct user access to data via the web-based system. BSA E-filing reduces processing time, provides controls to improve the accuracy, completeness, and security of BSA data. A Treasury Office of Inspector General audit found BSA E-Filing to be an effective mechanism for filing BSA reports and recommended its growth.

Evidence: FY 2006 Congressional Budget Submission pg. 6 and 15; Office of Inspector General Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's BSA E-Filing, page 5.

Is the program design effectively targeted so that resources will address the program's purpose directly and will reach intended beneficiaries?

Explanation: BSA data may only be disseminated in accordance with applicable legal requirements, policies, and guidelines established by the Director of FinCEN to: 1) identify possible criminal activity to appropriate law enforcement agencies; 2) support ongoing criminal financial investigations and prosecutions; 3) identify possible instances of BSA noncompliance; 4) evaluate and recommend possible uses of special currency reporting requirements; 5) determine emerging trends and methods of financial crimes; 6) support intelligence or counterintelligence activities; and 7) support government anti-money laundering initiatives. FinCEN follows these guidelines by establishing Memoranda of Understanding with users; requiring users of the information to undergo training; conducting on- and off-site inspections of data users; requiring recordkeeping; and ensuring users accurately answer a set of screen queries when accessing the data.

Evidence: 31 USC 5319, Chapter 53, subchapter II, subsection 5319; PATRIOT Act, Section 361, Subsection 310 (B); PATRIOT Act, Section 314(a); FinCEN's 314(a) Fact Sheet, pg 1.

Does the program have a limited number of specific long-term performance measures that focus on outcomes and meaningfully reflect the purpose of the program?

Explanation: This program has specific long-term performance measures that focus on the program's purpose and FinCEN's strategic goal to facilitate regulatory compliance, data management, and information sharing through e-government and Treasury's strategic objective to disrupt and dismantle the financial infrastructure of terrorists, drug traffickers, and other criminals. Measure #1 is the number of users directly accessing BSA data through FinCEN's web-based system and Measure #2 is the share of BSA filings submitted electronically. The more readily available, and accurate, BSA information is made to law enforcement, investigations can be conducted more effectively and efficiently. As this program is a process-oriented activity, these measures are proxy outcomes used to assess the program performance. In addition to the established measures above, FinCEN is looking at how to measure the quality of data collected and anticipates that the implementation of BSA Direct will improve both the data quality itself and the ability of FinCEN to track the data quality.

Evidence: FY 2006 Congressional Budget Submission pg. 15; FinCEN Strategic Plan FY 2006-2008 pgs 17 - 18; SAR Activity Review, Trends, Tips and Issues, Issue 7, pgs 30-36.

Does the program have ambitious targets and timeframes for its long-term measures?

Explanation: FinCEN has established ambitious targets and timeframes for its long-term measures. For example the FY2009 target projection of 10,000 users directly accessing BSA data through FinCEN's web based system shows substantial increases over the FY2001 performance level of 582. In FY2003, FinCEN began enhancements to its web-based system when the user baseline was 1,105. Additionally, for the share of BSA filings submitted electronically, the FY2008 target projection of 90% shows substantial increases over the FY2003 performance of 6%. This is ambitious given the five-year timeframe and baseline performance level.

Evidence: FY 2006 Congressional Budget Submission pg. 15; Exhibit 300, BSA Direct, Section 4, Performance Goals and Measures.

Does the program have a limited number of specific annual performance measures that can demonstrate progress toward achieving the program's long-term goals?

Explanation: FinCEN has a limited number of annual measures that track progress toward its long-term goal achievement. For the number of users directly accessing BSA data through FinCEN's web based system, the targets are incrementally increased to achieve the long-term target of 10,000 by 2009. For the share of BSA electronic filings, the annual targets are also incrementally increased to show progress in reaching the long-term target of 90% by FY 2008.

Evidence: FY 2006 Congressional Budget Submission pg. 15; Exhibit 300, BSA Direct, Section 4, Performance Goals and Measures.

Does the program have baselines and ambitious targets for its annual measures?

Explanation: The targets are ambitious based on the information used to determine each long-term measure and goal. For the two annual performance measures that incrementally track progress toward FinCEN's long-term performance goals, the annual targets are set to help FinCEN track its long-term progress and are based on resources and expected performance. The baseline for the annual target for the number of users directly accessing BSA data was set in FY2003 when FinCEN began enhancements to its web-based system. In FY2003, the user base was 1,105 and the ambitious annual targets are set to assess the progress toward the long-term goal of 10,000 by 2009. For the share of BSA electronic filings, the baseline was set at 6% for FY2003. In FY2003 the PATRIOT Act Communication System (PACS), now known as BSA Direct E-Filing, was implemented for the electronic filling of all BSA reports. The ambitious annual targets track the progress toward the long-term goal of 90% by 2008. Once the 90% goal is achieved, it is expected that the goal will be to maintain the 90% level.

Evidence: FY 2006 Congressional Budget Submission pg. 15; Exhibit 300, BSA Direct, Section 4, Performance Goals and Measures.

Do all partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) commit to and work toward the annual and/or long-term goals of the program?

Explanation: FinCEN partners with several contractors. The business cases for the projects associated with this program, BSA Direct, Secure Outreach, and BSA E-Filing, include performance measures that are linked to the program goals, and are a way of documenting program partners' commitment to support the goals of the program. In the contracts for BSA Direct and Secure Outreach the long-term performance goal for number of users accessing BSA information through the web-based system is included as part of the contract. The contractor for BSA E-Filing provides weekly performance reports about the number of E-Filings and enrollment on the system and monthly reports on the project activity. Regular reporting of this performance information is linked to tracking the progress for FinCEN's goal for increasing the percentage of E-Filers. FinCEN also has a specific Federal partner, the IRS' Detroit Computing Center (DCC), which collects data reported under the BSA, converts paper and magnetic tape submissions to electronic media, corrects errors in submitted forms, and maintains BSA data storage and retrieval systems. As evidenced in a December 7, 2004, memo, the IRS is committed to improving the current BSA collection processes to transition all BSA processing to a FinCEN modernized system.

Evidence: Measures; Exhibit 300, BSA E-Filing, Performance Goals and Measures; BSA Direct Contract, Section C.2, pg 6; Secure Outreach Contract, Section C.1, pg 1; and Informational Memorandum titled FinCEN and IRS Agreement on BSA Information Collection and Management, pgs. 2-3.

Are independent evaluations of sufficient scope and quality conducted on a regular basis or as needed to support program improvements and evaluate effectiveness and relevance to the problem, interest, or need?

Explanation: The 2003 GAP Analysis evaluation conducted by Deloitte & Touche, LLP studied the modernization of BSA processes and systems. The objective of the study was to compare the current BSA technology environment, including the workflow processes, to current and future technology alternatives. With the decision to move the full lifecycle of BSA management responsibilities from IRS to FinCEN, MITRE, Center for Enterprise Modernization, is conducting an assessment of FinCEN BSA E-Filing. This study is looking at how to enhance e-filing. The Treasury Office of the Inspector General conducted an audit to determine if the BSA E-filing system is an effective mechanism for filing BSA reports, and looked at how many institutions are using BSA E-filing to file BSA reports, and, for those not using BSA E-Filing, the reasons why. The Treasury OIG also conducted an audit to assess the status of FinCEN's implementation of their management corrective action plan in response to the IG's December 2002 report on the reliability of Suspicious Activity Reports.

Evidence: FinCEN GAP Analysis-Study for the Modernization of BSA Processes and Systems, pages 3-4; MITRE, Center for Enterprise Modernization, FinCEN BSA E-Filing Briefing Slides; Department of the Treasury, Office of the Inspector General, Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's BSA E-Filing, pages 33-34. OIG - FinCEN: Heightened Management Attention Needed Over Longstanding SAR Data Quality Problems

Are Budget requests explicitly tied to accomplishment of the annual and long-term performance goals, and are the resource needs presented in a complete and transparent manner in the program's budget?

Explanation: FinCEN's budget is performance-based and specifically ties to the accomplishment of its annual and long-term performance goals. Using the guidance and format of the Department of Treasury, FinCEN's Budget is presented programmatically to align resources with performance and to define the relationship between the performance targets and budget resources. FinCEN has two major budget activities: 1) BSA Administration and Analysis, and 2) Regulatory Support Programs. For each activity, in the Summary of Program Resources and Performance, budget and performance information are provided to explain historical trends, performance challenges, and expectations. Further performance planning information is included in the Performance Plan Section. This integrated budget and performance presentation clarifies the impact of funding, policy, and legislative changes on expected and past performance. Additionally, program increases are linked to relevant performance measures to show how changes in funding affect anticipated changes in performance.

Evidence: FY 2006 Congressional Budget Submission pgs. 14-28.

Has the program taken meaningful steps to correct its strategic planning deficiencies?

Explanation: Consistent with the new terrorism and financial intelligence focus of the Department of Treasury, FinCEN examined its strategic planning efforts and released an interim adjustment strategic plan. This plan charts the goals and objectives over the next three years given the challenges associated with the rapidly changing environment of combating financial crime. FinCEN is currently taking the following steps: 1) examining long-term and annual performance measures and targets to ensure that we are tracking the critical performance elements of the revised strategic plan; 2) focusing on outcome and efficiency measures that link to the mission and goals; and 3) providing FinCEN management with quarterly performance reports to make timely management decisions. With only 29 percent of the top 650 filers enrolled in BSA E-Filing, FinCEN has an outreach program to educate top filers about the system and its benefits and to offer assistance in transitioning to e-Filing.

Evidence: FinCEN Strategic Plan FY 2006-2008; FY 2006 Congressional Budget Submission pg 12 and 15; FinCEN Director's Quarterly Report.

Does the agency regularly collect timely and credible performance information, including information from key program partners, and use it to manage the program and improve performance?

Explanation: FinCEN regularly collects performance information on a quarterly basis. This information is entered into Treasury's Performance Reporting System. Currently, FinCEN is improving its internal reporting process to report performance data and project milestones to provide additional information to support management decisions on a regular basis. The contractor for BSA E-Filing provides weekly performance reports about the number of e-filings and enrollment in the system and monthly reports on the project. IRS regularly provides overall statistics that are combined with the contractor information to allow us to monitor the entire filing environment. These reports are used for planning for future projects, to measure the growth of the users and filings, and to figure out where improvement is needed. The BSA E-Filing contractors also provide statistical reports about the system usage; FinCEN can use this report for outreach or compliance.

Evidence: Print out of PRS; FinCEN Director's Quarterly Report, Weekly E-Filing Contractor Report; Monthly Contractor Report.

Are Federal managers and program partners (including grantees, sub-grantees, contractors, cost-sharing partners, and other government partners) held accountable for cost, schedule and performance results?

Explanation: FinCEN uses a variety of performance monitoring systems to track and enforce cost, schedule, and performance results by FinCEN staff and its partners. The business cases (Exhibit 300) for the projects (BSA Direct, Secure Outreach, and E-Filing) include cost and schedule tracking information. Projects are reviewed on a quarterly basis by the Treasury Capital Planning and Investment Control Process. The FinCEN contracting officer's representative monitors the performance on a regular basis and brings performance issues to the contractor's attention. Starting in 2005, FinCEN senior managers had program performance elements that tie to goal achievement written into their performance plans. Success with these performance elements will be ranking criteria for the managers' yearly performance ratings. These performance plans are an additional method for tracking program performance and making timely management decisions. However, the IRS activities are not directly accountable to us and outside the scope of our performance measures. After the IRS functions are within FinCEN, under BSA Direct, those activities will also be reflected in FinCEN performance results.

Evidence: Exhibit 300 BSA E-Filing, Section I.H; Exhibit 300 Secure Outreach Network, Section I.H; Exhibit 300, BSA Direct, Section I.H.; Senior Management Performance Plan.

Are funds (Federal and partners') obligated in a timely manner and spent for the intended purpose?

Explanation: All FinCEN's programs and associated resources are obligated consistent with its overall mission and support its strategic plan. FinCEN's resource and acquisition review processes ensure that resources are used for the programs for which they are intended. All proposed acquisitions are subject to a multi-level review process. All acquisitions are reviewed by the program/project officer, Division Director or Assistant Director, and by the Deputy CFO. All acquisitions over the $25,000 threshold are approved by the Deputy Director of FinCEN. All funds are reviewed on a quarterly basis by the CFOs office to ensure funds are obligated timely and in accordance with the funding plan, which is approved by the Deputy Director. FinCEN plans for an unobligated lapse of approximately 0.5% of estimated obligations for potential adjustments needed in future years.

Evidence: Standard Object Class Table; RMS reports-obligations/expenditures-sample attached; SF-132 (Apportionment); SF-133 (Report on Budget Execution).

Does the program have procedures (e.g. competitive sourcing/cost comparisons, IT improvements, appropriate incentives) to measure and achieve efficiencies and cost effectiveness in program execution?

Explanation: The program's long-term measures track the efficiency of the program. FinCEN has been able to show substantial increases in the number of users directly accessing BSA data and the share of BSA filings submitted electronically. Although not discussed as part of this program, the more users accessing BSA data directly reduces the number of lower value analytical efforts required to otherwise retrieve the BSA data for these users. The increases in BSA forms electronically filed ensure that the law enforcement information is more quickly available. Additionally, the Treasury OIG found BSA E-Filing to be an effective mechanism for filing BSA reports and estimates the annual cost avoidance of filing paper BSA reports to be $16 million. FinCEN has developed an efficiency measure to show cost savings: costs per BSA form e-filed. This measure tracks the number of BSA forms e-filed against the reoccurring costs associated with operations and maintenance of e-filing. It is anticipated that as the number of BSA forms e-filed increases, the cost per form to the Federal government will decrease. IT Investment Plans (Exhibit 300s) also include these two measures and plan for increased efficiencies. These plans also track the project's cost and schedule milestones. This information is examined quarterly as part of Treasury's investment review.

Evidence: FY 2006 Congressional Justification, pg 15; Office of Inspector General Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's BSA E-Filing, pg 12; Exhibit 300 BSA E-Filing, Section I.C and Section I.H; Exhibit 300 Secure Outreach Network, Section I.C and Section I.H; Exhibit 300, BSA Direct, Section I.C and Section I.H.

Does the program collaborate and coordinate effectively with related programs?

Explanation: FinCEN collaborates effectively with similar programs and stakeholders. The networking done through FinCEN with law enforcement and regulatory agencies is long-standing. FinCEN has many Memoranda of Understanding (MOU) with law enforcement at all levels across the country for information sharing and retrieval. This includes MOUs with all 50 States and several local law enforcement communities, several Federal partners (e.g., FBI, DEA, ATF and US Postal Service), and FinCEN is in the process of establishing MOUs with additional Federal partners. Our collaboration with law enforcement has resulted in increased usage of the BSA databases. To support this additional usage, we had a FY2005 program increase of four positions to provide support for training, alerts, and overall increased customer interface. Additionally, FinCEN cooperates with a number of other Treasury organizations/agencies such as Office of Foreign Asset Control and the Treasury OCIO to share information and collaborate on IT projects.

Evidence: MOUs for Office of Foreign Asset Control (OFAC); United States Food and Drug Administration, Office of Criminal Investigations; Chicago, High Intensity Drug Tracking Area (HIDTA), Illinois State Police; and FY 2005 FinCEN Congressional Budget Justification, pg 10; and Informational Memorandum titled FinCEN and IRS Agreement on BSA Information Collection and Management, pgs. 2-3.

Does the program use strong financial management practices?

Explanation: FinCEN operates in accordance with the procedures and standards prescribed by the Comptroller General and Office of Management and Budget guidelines. The systems of management control for FinCEN are designed to ensure that: programs achieve intended results; performance information is reliable; resources are used consistent with overall mission; programs and resources are free from waste, fraud, and mismanagement; laws and regulations are followed; controls are sufficient to minimize any improper or erroneous payments; system security is in substantial compliance with all relevant requirements; continuity of operations planning in critical areas is sufficient to reduce risk to reasonable levels. FinCEN's management control systems provide reasonable assurance that FinCEN is in compliance with the Federal Managers' Financial Integrity Act. Because FinCEN is not material to Treasury, its financial statements have not been audited. However, an SAS 70 review is performed annually by an independent public accountant on accounting and general computer controls of the Bureau of Public Debt-Administrative Resource Center, Accounting Service Division and in the latest review found no instances of reportable noncompliance with laws and regulations tested.

Evidence: FinCEN's FY 2004 Assurance Statement; Treasury Accountability Report. August 19, 2005, Treasury OIG Report OIG-05-044, Report on Controls Placed in Operation and Tests of Operating Effectiveness for the Treasury Bureau of Public Debt Administrative Resource Center for the Period July 1, 2004 to June 30, 2005.

Has the program taken meaningful steps to address its management deficiencies?

Explanation: FinCEN's implementation of the GAP Analysis recommendations led to a decision to build BSA Direct (and bring all processes under FinCEN's purview). At the time of this review, most of the processes were under IRS-DCC's control and the most critical finding in the GAP analysis involved the need to take more ownership of the BSA collection and retrieval processes. Although FinCEN continues to work toward implementing many of the principles outlined in the GAP Analysis, there have been several areas where the implementation has been completed, including: implementation of BSA data quality and integrity improvements; approval to jointly plan with IRS to consolidate control over BSA Processing and Hosting; expansion of e-filing with more forms and additional functionality; modification of E-Filing to enable batch uploads of discrete forms; enabling institutions to test their filings before they start using the system; adoption of Visual Links for basic and advanced analysis; expansion of tools to include capabilities similar to Digital Information Gateway; and capturing all BSA data into Visual Links databases. FinCEN also recently reorganized to combine user community liaisons, technical project oversight, and service provider oversight into one management team under a single Associate Director. In response to the recent OIG study on e-filing, FinCEN is taking or plans to take the following corrective actions: 1) expand outreach efforts with the financial industry and others to move the top filers to e-filing (June 2005); 2) evaluate and select for implementation BSA E-Filing enhancements required to assure the system can meet future E-Filing volume (February 2006); and 3) evaluate the feasibility of mandating E-Filing of BSA reports (December 31, 2005). In response to the recent OIG report on SAR data quality, FinCEN has outlined steps to improve the completeness of the SAR data. Specifically related to this program are the front-end data check capabilities that will assist in ensuring critical fields are complete, once identified, with target for completion in December 2005.

Evidence: U.S. Department of Treasury, Financial Crimes Enforcement Network GAP Analysis-Study for the Modernization of BSA Processes and Systems; Department of the Treasury, Office of the Inspector General, Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's E-Filing, pg. 31; FinCEN Management Response to Audit of BSA E-Filing and Audit of SAR Data Quality

Has the program demonstrated adequate progress in achieving its long-term performance goals?

Explanation: FinCEN is making good progress in meeting its long-term performance goals for number of users directly accessing BSA data through FinCEN's web based system and the share of BSA filings submitted electronically. FinCEN began tracking these measures against a target in FY2003. For both measures, FinCEN met the FY2003 and FY2004 targets and the historical information shows substantial progress. For example, the number of users directly accessing BSA data through the web based system has increased from 582 in FY 2001 to 2,181 in FY 2004, surpassing the FY 2004 target of 1,700. For the share of BSA filings submitted electronically, such filings have increased from 6% in FY2003 to 20% in FY2004, meeting the FY2004 target of 20%. FinCEN believes these are ambitious targets given its trend data and the rapidly changing demands of tracking financial crime.

Evidence: FY 2006 Congressional Budget Submissions: Treasury Performance and Accountability Report, pgs 292-295

Does the program (including program partners) achieve its annual performance goals?

Explanation: FinCEN has met its annual performance goals associated with its long-term performance measures for directly accessing BSA data through FinCEN's web based system and share of BSA filings submitted electronically. The number of users directly accessing BSA information through the web-based system has increased from 582 in FY2001 to 2,181 in FY2004, surpassing the FY2004 target of 1,700. For the share of BSA filings submitted electronically, such filings have increased from 6% in FY2003 to 20% in FY2004, meeting the FY2004 target of 20%. Additionally, many of FinCEN's partners report performance information that is critical to monitoring the progress of FinCEN's annual and long-term measures.

Evidence: FY 2006 Congressional Budget Submission, pg. 15: FY 2004 Treasury Performance and Accountability Report, pgs. 292-295.

Does the program demonstrate improved efficiencies or cost effectiveness in achieving program goals each year?

Explanation: The program can show improved efficiencies and cost effectiveness for collecting and sharing BSA data. For instance, FinCEN has been able to show substantial increases in the number of users directly accessing BSA data and the share of BSA filings submitted electronically. Additionally, the OIG found BSA E-Filing to be an effective mechanism for filing BSA reports. The system reduces processing time, provides controls to improve accuracy, completeness, and security of BSA data. The BSA Direct and Secure Outreach projects associated with this program have been able meet the cost and schedule milestones, not exceeding the 10% variance prescribed by OMB's Capital Planning Investment Control Guidelines. The historical data from the newly established efficiency measure, Cost per BSA Form E-Filed, has shown improved cost effectiveness. Modernization of the E-Filing system began in FY2003 when the cost per BSA form E-Filed was $2.28. In 2004 the cost decreased to $ 0.64. Further cost efficiencies are expected as volume increases.

Evidence: FY 2006 Congressional Budget Submission pg 15; Office of Inspector General Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's BSA E-Filing, pg 12. ; Exhibit 300 BSA Direct, Section I.H; Exhibit 300 Secure Outreach Network, Section I.H.

Does the performance of this program compare favorably to other programs, including government, private, etc., with similar purpose and goals?

Explanation: The program's processes are more comparable to industry processes and the GAP Analysis made this kind of comparison. The stated objective of the GAP Analysis was to compare the current BSA technology environment, including the workflow processes, to the technology alternatives that are available today and into the future. The current environment looked at data processes and systems at FinCEN and IRS-DCC. The study observed gaps and overlaps in the systems and processes. It also provided recommendations to improve the management of BSA processes based on industry best practices. The recommendations were aligned with the goal of modernizing BSA processes and systems to meet FinCEN's growing demand to support financially related law enforcement inquiries, regulatory support, and trend analysis. This led FinCEN to establish BSA Direct and enhance other BSA processes.

Evidence: U.S. Department of Treasury, Financial Crimes Enforcement Network GAP Analysis-Study for the Modernization of BSA Processes and Systems, page 7-8.

Do independent evaluations of sufficient scope and quality indicate that the program is effective and achieving results?

Explanation: In its evaluation of BSA E-Filing, Treasury OIG's found it to be an effective mechanism for filing BSA reports with reduced processing times, controls to improve the accuracy, completeness, and security of BSA data, a reduction in the cost of processing BSA reports, and an easy system to use. The OIG did recommend that FinCEN conduct additional outreach among potential BSA E-Filing users. In a separate audit report, the OIG presented several problems with, and made several recommendations to help improve, the quality of SAR data quality.

Evidence: Office of Inspector General Terrorist Financing/Money Laundering: Additional Outreach and System Enhancements are Needed to Encourage Greater Use of FinCEN's BSA E-Filing, page pgs 4-5; U.S. Department of Treasury, Financial Crimes Enforcement Network GAP Analysis-Study for the Modernization of BSA Processes and Systems, page 7-8. OIG - FinCEN: Heightened Management Attention Needed Over Longstanding SAR Data Quality Problems