BSA stands for the Bank Secrecy Act. SARs stands for Suspicious Activity Reports. Listed below is a summary of the evolution of the Bank Secrecy Act.

The Law

Before the Patriot Act

• BSA of 1970 - required banks to file CTRs on single cash transactions in excess of $10,000
• April 1996 – required banks to file SARs to FinCEN reporting known or suspected criminal offenses or a transaction that a bank suspects involves money laundering or violates the BSA
• Focus on drug trafficking

After the Patriot Act

• Title III expanded the scope of BSA to focus on terrorist financing
• Section 313/319 restricts business dealings with foreign banks
• Section 314 requires banks to share confidential information with federal agencies investigating terrorist activity or money laundering
• Effective Oct. 1, 2003, Section 326 requires financial institutions to develop a customer identification program.   This includes the verification of the identity of the customer (name, DOB, address, SSN) as well as determining whether the customer appears on the Office of Foreign Assets Control (OFAC) list.
• Section 327 establishes a review of an institution’s Anti-Money Laundering record in approving mergers, acquisitions or other activity under the Bank Holding Company Act or Federal Deposit Insurance Act
• Sections 365 requires businesses to file CTRs for large cash transactions
• Added requirements for casinos, money services businesses and registered broker/dealers to file SARs and CTRs 
• Establishment of internal controls including an appointed BSA officer and board responsibility