Business Law Financial Institutions Committee Update

Proposed STREAMLINE Act Would Modernize the Bank Secrecy Act’s Financial Reporting Requirements by Raising BSA’s Reporting Thresholds

October 30, 2025

Dear constituency list members of the Financial Institutions Committee,

The following is a bulletin prepared by Stefan Lawrence, Counsel at Early Warning Services, LLC.

Summary

On October 21, 2025, Senators John Kennedy (R-LA) and Tim Scott (R-SC) introduced the STREAMLINE Act – “Streamlining Transaction Reporting and Ensuring Money Laundering Improvements for a New Era Act” – to significantly increase the reporting thresholds for Currency Transaction Reports (CTRs) and Suspicious Activity Reports (SARs) under the Bank Secrecy Act (BSA), which have remained unchanged for over 50 years.

Currency Transaction Reports (CTRs)

• Current Threshold: Financial institutions must file a CTR for cash transactions exceeding $10,000.
• Proposed Threshold: The STREAMLINE Act would raise the CTR reporting threshold to $30,000.
• Rationale: The existing limit, established in 1970, is widely considered outdated. The increase would reduce the volume of low-value, routine reports, allowing law enforcement to focus on more significant financial crimes.

Suspicious Activity Reports (SARs)

• Current Thresholds: Financial institutions are required to file SARS for suspicious activity involving the following monetary amounts: $5,000 for banks; $2,000 for money service businesses (MSBs).
• Proposed Thresholds: The STREAMLINE Act would raise these amounts to $10,000 and $3,000, respectively.
• Rationale: These increased thresholds would help reduce compliance burdens on financial institutions and allow law enforcement to focus on more targeted, useful information.

Additional Provisions; Next Steps

• Inflation Adjustments: The bill mandates that the Treasury Department adjust these reporting thresholds every five years to account for inflation, ensuring the amounts remain relevant.
• Review of Reporting Forms: The proposed legislation further calls for a review of existing reporting forms to reduce redundancy and improve the automation of the reporting process while maintaining security.
• Support for the Bill: These changes are supported by major financial industry trade groups, including the American Bankers Association and America’s Credit Unions.

Credits & Contact

Financial Institutions Committee

Chair Jason Shafer