FinCEN Year in Review FY 2024

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FinCEN Year in Review for FY 2024 2 Bank Secrecy Act (BSA) Data Advances Law Enforcement Missions1 Financial intelligence generated by BSA reporting is a critical source of information used in investigations and prosecutions of financial crimes, money laundering predicate offenses, and other illegal activities. FinCEN’s law enforcement partners report extensive use of BSA information to generate new leads and advance existing investigations. Internal Revenue Service – Criminal Investigation (IRS-CI) IRS-CI identifies BSA data as a critical element of its complex cases and the vast majority of these cases are searched against BSA data. IRS-CI cited the following statistics: Federal Bureau of Investigation (FBI) The FBI leverages Suspicious Activity Reports (SARs) and Currency Transaction Reports (CTRs) in a significant percentage of major cases across priority crime areas. FBI case program FBI subjects with SARs in FY24 SAR count in FY24 FBI subjects with CTRs in FY24 CTR count in FY24 Percentage of active FBI investigations linked to SARs/CTRs Complex Financial Crime Program 5,715 11,660 2,243 11,268 32% International Terrorism Program 409 772 214 947 16.2% Organized Crime Drug Enforcement Program 2,838 4,690 1,782 6,566 40% Public Corruption Program 1,089 2,031 665 2,555 24.7% Transnational Organized Crime Program 1,844 3,652 1,145 6,740 20.8% Homeland Security Investigations (HSI) In FY24, HSI personnel conducted approximately 290,000 queries related to BSA reporting. Financial analysis of BSA reporting benefited the vast majority of the following in FY24: Programmatic areas considered primarily financial in nature: Across all programmatic areas: 3,500+ new investigations 27,000+ new criminal investigations 2,200+ criminal arrests $1.2 billion seized 800+ convictions 29,000+ arrests 9,000+ convictions 1 All statistics in this infographic are approximate.

FinCEN Year in Review for FY 2024 3 Law Enforcement Awards Program The annual FinCEN Law Enforcement Awards Program recognizes investigative and prosecutorial teams that effectively leveraged BSA reporting. The awards demonstrate the value of BSA reports to law enforcement efforts to protect the public and financial system. Number of awards presented Number of successfully prosecuted cases nominated Number of BSA filings reviewed in nominated cases Number of filing institutions that filed reports that supported nominated cases Number of convictions resulting from nominated cases Number of law enforcement agencies that supported nominated cases 7 37 8,582 339 178 45 Reports Pursuant to the BSA FinCEN receives reports from approximately 324,000 registered financial institutions and other e-filers in support of criminal justice and national security objectives.2 Forms FY 2022 FY 2023 FY 2024 Average Daily Filings FY24 Suspicious Activity Reports (SARs) 4.3M 4.6M 4.7M 12,870 Currency Transaction Reports (CTRs) 20.6M 20.8M 20.5M 56,160 Currency and Other Monetary Instrument Reports (CMIRs) 128,100 143,200 152,100 417 Reports of Cash Payments >$10K Received in a Trade or Business (Form 8300) 431,800 421,500 470,400 1,290 Foreign Bank and Financial Accounts (FBARs) 1.5M 1.6M 1.7M 4,660 2 M = Million 3 The “other” category includes filings by depository institution holding companies; dealers in precious metals, precious stones, or jewels; operators of credit card systems; and housing government sponsored enterprises. 4 An individual SAR may have more than one SAR activity type, and therefore the sum total of the corresponding graph exceeds the total number of SAR filings. FY24 SARs by Type of Financial Institution3 FY24 SAR Activity Type4 SARs: The top 10 filers of SARs filed approximately 45% of all FY24 SARs.

FinCEN Year in Review for FY 2024 4 314(a) and 314(b) Information Sharing Programs Section 314(a) Requests Section 314(a) of the USA PATRIOT Act enables federal, state, local, and certain foreign law enforcement agencies, through FinCEN, to reach out to financial institutions to locate accounts and transactions associated with persons that are reasonably suspected based on credible evidence of terrorism or money laundering. Section 314(b) Section 314(b) of the USA PATRIOT Act permits registered financial institutions to share information with one another in order to identify money laundering or terrorist activity, and to report any identified suspicious activity to FinCEN. Section 314(b) in FY24 6,100+ 314(b) registered financial institutions 1,693 Financial institutions referenced 314(b) in SAR narratives 48,223 SARs that referenced 314(b) 62 Terrorism-related SARs referenced 314(b) The number of 314(b) registered financial institutions

FinCEN Year in Review for FY 2024 5 FinCEN Information Access and Use In addition to the nearly 400 analytical intelligence reports that FinCEN provided to law enforcement and other customers in FY24, FinCEN provides select authorized partners with direct access to BSA data in support of investigations and prosecutions. Authorized Access to BSA Data in FY245 Authorized users conducted over 2.3 million searches using BSA Search, a tool that allows users to access, query, and analyze BSA data. Collectively, 432 federal, state, and local law enforcement, regulatory, and national security agencies have access to BSA reports and BSA Search, and over 12,000 authorized personnel have access to BSA data. 5 Due to recent changes impacting the Beneficial Ownership Information (BOI) reporting program, BOI-related statistics are excluded from these metrics. 6 There are more than 12,000 Portal users. Survey non-response bias may impact the accuracy of results. BSA Training for Law Enforcement BSA Users Trained: 20,600 BSA Training Programs Offered: 494 FinCEN’s training team conducted extensive outreach to authorized BSA Search users to enhance their ability to effectively use BSA information in the course of their investigations. Results from FinCEN’s FY24 Portal Query Performance Measure Survey More than 1,400 FinCEN Portal users completed a user satisfaction survey in F24:6

FinCEN Year in Review for FY 2024 6 U.S. Financial Institution Advisory Program and Financial Trend Analyses (FTAs) FinCEN, through its Advisory Program, communicates priority money laundering, terrorist financing, and other illicit finance threats and vulnerabilities to the U.S. financial system. Financial institutions may use this information to support effective, risk-based, and reasonably designed anti-money laundering and countering the financing of terrorism (AML/CFT) programs and suspicious activity monitoring systems to help generate highly useful information for law enforcement and national security agencies. Product Product Identification Numbers and Key Terms Date of Publication Number of SAR filings in FY24 Alert: Counter Financing to Hamas and its Terrorist Activities #FIN-2023-Alert006 FIN-2023-TFHAMAS 10/20/23 320 Notice: Global Export Control Evasion #FIN-2023-NTC2 FIN-2023- GLOBALEXPORT 11/6/23 250 Alert: COVID-19 Employee Retention Credit Fraud #FIN-2023-Alert007 FIN-2023-ERC 11/22/23 1,250 Notice: Counterfeit U.S. Passport Cards to Perpetrate Identity Theft and Fraud Schemes #FIN-2024-NTC1 FIN-2024-NTC1 4/15/24 210 Advisory: Countering the Financing of Iran￾Backed Terrorist Organizations #FIN-2024-A001 IRANTF-2024-A001 5/8/24 30 Advisory: Supplemental Illicit Fentanyl and Other Synthetic Opioids #FIN-2024-A002 FENTANYL FIN￾2024-A002 6/20/24 70 Notice: Timeshare Fraud Associated with Mexico-Based Transnational Criminal Organizations #FIN-2024-NTC2 FIN-2024-NTC2; TIMESHAREMX 7/16/24 90 Additionally, pursuant to section 6206 of the Anti-Money Laundering Act of 2020 (AMLA), which requires FinCEN to periodically publish threat pattern and trend information derived from BSA filings, FinCEN published Financial Trend Analysis Reports to highlight priority illicit finance risks as well as the value of BSA reporting. Financial Trend Analysis Reports Date of Publication Identity-Related Suspicious Activity: 2021 Threats and Trends 1/9/24 Use of Convertible Virtual Currency for Suspected Online Child Sexual Exploitation and Human Trafficking: Threat Pattern & Trend Information, January 2020 to December 2021 2/13/24 Elder Financial Exploitation: Threat Pattern & Trend Information, June 2022 to June 2023 4/18/24 Mail Theft-Related Check Fraud: Threat Pattern & Trend Information, February to August 2023 9/9/24

FinCEN Year in Review for FY 2024 7 Public-Private Partnership Engagement FY24 FinCEN Exchange is a voluntary public-private information-sharing partnership among law enforcement agencies, national security agencies, financial institutions, other relevant private sector entities, and FinCEN to enable the private sector to better identify risks and provide FinCEN and law enforcement with critical information to disrupt money laundering, terrorism financing, and other financial crimes. 14 FinCEN Exchange Events International Programs Rapid Response Program (RRP) FY24 Through the RRP, FinCEN partners with law enforcement and leverages the Egmont network to help victims and their financial institutions recover funds stolen as a result of certain cyber-enabled financial crime schemes, including business e-mail compromise. Egmont Information Sharing FinCEN routinely shares and receives information with other members of the Egmont Group of Financial Intelligence Units, a global network of financial intelligence units, to support money laundering and other financial crimes investigations at home and abroad. Egmont Information FY24 Member Countries 177 Incoming Requests from Foreign FIUs 972 Request Responses 863 Outgoing Requests to Foreign FIUs 452 Outgoing Spontaneous Disclosures 212 Incoming Spontaneous Disclosures 1,028

FinCEN Year in Review for FY 2024 8 Special Measures Through Section 311 of the USA PATRIOT Act and Section 9714 of the Combating Russian Money Laundering Act, FinCEN may impose “special measures” addressing foreign financial institutions, classes of transactions, or types of accounts of “primary money laundering concern.”7 Section 311 also allows FinCEN to impose special measures on foreign jurisdictions of primary money laundering concern. 311 Actions in FY24 9714 Action in FY24 Convertible Virtual Currency Mixing (Notice of proposed rulemaking published on October 19, 2023) PM2BTC (September 26, 2024) Al-Huda Bank (Final rule published on July 3, 2024) ABLV Bank (Rescinded on September 26, 2024) Enforcement Actions FinCEN maintains overall authority for enforcement of the BSA and conducts investigations of financial institutions, non-financial trades and businesses, and individuals for engaging in violations of the BSA. FinCEN receives tips from whistleblowers related to violations of the BSA and other authorities. In November 2023, FinCEN announced the largest ever settlement in U.S. Department of the Treasury history, assessing a $3.4 billion civil money penalty against Binance Holdings Ltd. and several affiliates. Civil Money Penalties Issued in FY24 Value of Civil Money Penalties New Whistleblower Tips, Complaints, and Referrals Evaluated 2 $3,400,100,000 127 7 Section 9714 requires that the primary money laundering concern be in connection with Russian illicit finance.