Parallax Research Atlas Edition 2026-10

Bank Secrecy Act

Edition label: 2026-10

Definition: The Currency and Foreign Transactions Reporting Act of 1970 (codified at 31 U.S.C. § 5311 et seq.), commonly the Bank Secrecy Act (BSA) — the principal U.S. federal statute requiring financial institutions to maintain records of, and file reports on, transactions that may indicate money laundering, tax evasion, or other criminal activity.1

Overview

The BSA establishes the federal anti-money-laundering recordkeeping and reporting framework administered by the U.S. Treasury’s Financial Crimes Enforcement Network (FinCEN).2 Two mandatory reporting mechanisms are:

The SAR deadline is generally 30 calendar days after initial detection of facts that may constitute a basis for filing, and may extend to 60 days only if no suspect is identified.5

The BSA is the legal architecture that frames the Epstein financial-institution failure pattern described in the cited records. The cited congressional records describe a Suspicious Activity Report (SAR) asymmetry at JPMorgan, though they differ on the numbers: Senator Wyden’s memorandum says JPMorgan filed 7 SARs flagging $4.3 million between 2002 and 2016, then two SARs in August and September 2019 flagging more than 5,000 wire transfers totaling about $1.3 billion, while Representative Raskin’s letter says JPMorgan filed no SAR during the relationship and, after Epstein’s death, filed SARs covering 4,700 transactions totaling $1.1 billion.6 The Bank of America complaint alleges SAR-filing failures.7

Source References

Open Questions