CI-FIRST enhances information-sharing with financial institutions
Date: March 28, 2025
Contact: [email protected]
WASHINGTON – IRS Criminal Investigation (IRS-CI) released investigative statistics March 28 highlighting how the agency uses Bank Secrecy Act (BSA) data to investigate financial crimes. During the previous three fiscal years 2022-2024 (FY22-24), 87.3% of IRS-CI’s criminal investigations recommended for prosecution had a primary subject with a related BSA filing, and adjudicated cases resulted in a 97.3% conviction rate with defendants receiving average prison sentences of 37 months. IRS-CI also used BSA data to identify $21.1 billion in fraud tied to tax and financial crimes, seize $8.2 billion in assets tied to criminal activity, and obtain $1.4 billion in restitution for crime victims.
Under the BSA, financial institutions use suspicious activity reports (SARs) to notify the federal government when they encounter instances of potential money laundering or tax evasion. This data is used by federal agencies like IRS-CI to investigate money laundering and related financial crimes.
“Public-private partnerships thrive when everyone mutually benefits, and to enhance our partnership with the financial industry, we plan to launch CI-FIRST which will promote information-sharing, streamline processes and demonstrate how valuable BSA data is to criminal investigations,” said IRS-CI Chief Guy Ficco.
CI-FIRST (Feedback in Response to Strategic Threats) is a new IRS-CI initiative that will establish ongoing engagement with financial institutions. The program will ensure that financial institutions receive quantifiable results from IRS-CI on how the agency uses suspicious activity reports (SARs) to investigate federal crimes. As part of this program, IRS-CI will also streamline subpoena requests and share pointers with financial institutions on what to include in SARs to maximize impact. CI-FIRST will serve as an opportunity to address what’s working and what can be improved, creating continuous lines of communication between partners. IRS-CI headquarters will work with larger financial institutions that have a national and international presence, and field office personnel will work with regional and community banks and credit unions in their respective areas of responsibility.
“The lack of constructive feedback on SARs has long been a major barrier to a more effective approach to disrupting criminal networks in the U.S. and abroad. CI-FIRST has the potential to drive higher quality information for law enforcement and a better distribution of resources in the fight against financial crime, demonstrating how feedback can be provided and incorporated at scale,” said J. Edward Conway, executive secretary at the Wolfsberg Group.
IRS-CI special agents ran an average of 966,900 searches annually against currency transaction reports during the last three fiscal years. Nearly 1,600 cases were opened in FY24 with at least one currency transaction report on the primary subject. The data also indicates that 67.4% of cases opened by IRS-CI had a subject with one of more currency transaction reports below $40,000, with 50% of currency transaction reports involving amounts less than $22,230.
BSA data has also proven effective in helping IRS-CI combat narcotics trafficking and pandemic-era tax fraud. Since FY20, IRS-CI used BSA data to initiate nearly 1,300 investigations with ties to fentanyl and investigate alleged employee retention credit fraud totaling $5.5 billion.
IRS-CI is the law enforcement arm of the IRS, responsible for conducting financial crime investigations, including tax fraud, narcotics trafficking, money-laundering, public corruption, healthcare fraud, identity theft and more. IRS-CI is the only federal law enforcement agency with investigative jurisdiction over violations of the Internal Revenue Code, obtaining a 90% federal conviction rate. The agency has 20 field offices located across the U.S. and 14 attaché posts abroad.