By Jason Stverak
Congress does not need another warning that the Bank Secrecy Act’s reporting thresholds are obsolete. It needs to act.
H.R. 1799, the Financial Reporting Threshold Modernization Act, was approved by the House Financial Services Committee on January 22. The committee report was filed on March 19, placing the bill on Union Calendar No. 478. Since then, it has waited for House floor action. That is not a policy problem. It is a scheduling problem, and congressional leaders should solve it before another year ends with a widely recognized reform left unfinished. (GovInfo)
The Defense Credit Union Council strongly supports the Bank Secrecy Act and the role financial institutions play in combating money laundering, fraud, terrorist financing, sanctions evasion, and other illicit activity. Defense credit unions understand that financial security is national security. They serve servicemembers, veterans, military families, and communities whose trust must be protected.
But supporting the mission of the BSA does not require defending every requirement exactly as it was written decades ago. Effective enforcement depends on useful information, not the largest possible pile of reports.
The current $10,000 Currency Transaction Report threshold was established in 1972 and has never been adjusted for inflation. The Government Accountability Office calculated that an inflation-adjusted threshold would have been approximately $72,880 in 2023. GAO also found that CTR filings increased about 62% since fiscal year 2002, while law enforcement accessed only about 5.4% of the reports filed from 2014 through 2023 through FinCEN’s portal. In the most recent full year GAO examined, agencies accessed less than 3% through the portal or their internal systems. (Government Accountability Office)
Those figures do not mean CTRs lack value. They mean Congress should improve the signal-to-noise ratio. When routine, lawful transactions generate millions of automatic reports, compliance professionals spend time documenting activity that poses little identifiable risk, while investigators must search an expanding universe of data for the transactions that truly matter.
H.R. 1799 provides a targeted correction. It would raise the CTR threshold from $10,000 to $30,000; increase applicable Suspicious Activity Report thresholds from $5,000 to $10,000 and from $2,000 to $3,000; and update the thresholds for inflation every five years. It also directs Treasury, in consultation with law enforcement and private-sector stakeholders, to examine reporting forms, aggregation rules, prioritization, and automation so the system becomes more efficient at identifying illicit finance. (GovInfo)
That last provision is important. This bill is not a retreat from enforcement. It requires a better enforcement architecture. It does not erase the BSA, excuse structuring, eliminate customer due diligence, or end targeted information sharing. DCUC has consistently supported effective tools such as the Section 314(a) process while urging regulators to replace indiscriminate volume with clearer, risk-based requirements.
For defense credit unions, this is not an abstract compliance debate. Institutions serving military communities frequently operate with lean teams while managing complex member needs, overseas assignments, permanent changes of station, deployments, emergency transfers, and legitimate cross-border activity. Every staff hour consumed by low-value paperwork is an hour unavailable for fraud prevention, financial counseling, affordable credit, emergency assistance, or helping a military family navigate a financial crisis.
Modernization also protects privacy. A government reporting system should not collect information about ordinary Americans simply because inflation transformed yesterday’s extraordinary transaction into today’s routine purchase, vehicle sale, home repair, or small-business deposit. Reporting thresholds should identify risk, not merely reflect economic conditions from more than half a century ago.
DCUC has repeatedly urged Congress to move this legislation, including through the annual defense authorization process. Our position has remained consistent: preserve the tools that produce actionable intelligence, modernize thresholds that sweep in routine conduct, clarify aggregation requirements, and consult military-serving institutions before imposing major new compliance expectations on their operations.
There is no serious fiscal excuse for delay. The Congressional Budget Office estimated that H.R. 1799’s net effect on the federal deficit would be insignificant. Congress can deliver substantial operational relief, improve data quality, strengthen privacy, and preserve law enforcement access to genuinely useful information at minimal federal cost. (Congressional Budget Office)
The path forward is straightforward. House leadership should bring H.R. 1799 to the floor. If standalone floor time remains scarce, congressional leaders should include these reforms in the next viable financial-services package or in the final Fiscal Year 2027 National Defense Authorization Act. (GovInfo)
Using the NDAA would not be unusual. Congress enacted the Anti-Money Laundering Act of 2020 through the Fiscal Year 2021 NDAA, and that law directed Treasury and FinCEN to review reporting requirements. H.R. 1799 would require completion of overdue reviews while making the threshold changes that evidence already supports.
Congress often says it wants regulation to be smarter, government data to be more useful, privacy to be respected, community institutions to be protected, and national-security resources to be focused on genuine threats. H.R. 1799 advances every one of those goals.
The bill has completed the hard committee work. The evidence is established. The need is clear. Congress should stop allowing this commonsense modernization to sit on a calendar and finish the job.
Jason Stverak is Chief Advocacy Officer at the Defense Credit Union Council.