In my previous blog I looked at the practical implications of the FAQs regarding Suspicious Activity Reporting Requirements issued by key U.S. financial regulatory bodies in October 2025. Nasdaq Verafin brought together a dedicated Customer Advisory Group (CAG), including AML leaders from several mid-sized financial institutions, to share their perspectives and analyze the real-world implications of the newly issued FAQs. While not covered by the FAQs, the discussion naturally turned to the proposed Streamline Act, which could raise SAR and CTR filing thresholds.
The Streamline Act Impact
The numbers are dramatic. Banks reported that a CTR threshold increase to $30,000 could eliminate 75% to 94% of their current filings. However, the operational reality is more complex.
A member of the CAG discussion noted the disparity between volume reduction and actual resource savings: “We’re at like 80 percent reduction on CTRs, but that’s going to save me like a quarter of a person because of how automated that process is… I am nervous of that perception because that’s exactly how this act will be represented in the media, as they’ve completely modernized BSA by raising the thresholds.”
SAR Thresholds – A Modest Impact
Raising the SAR threshold from $5,000 to $10,000 would have a much less significant impact, with estimated reductions in filings around 10-15%.
These potential changes pose a critical challenge for BSA leaders – managing executive expectations. The headline-grabbing reduction in filing volume does not translate to a proportional reduction in operational cost or staff, as these processes are already highly automated. Ian Rudebusch, Principal Product Manager at Nasdaq Verafin, who specializes in Anti-Money Laundering (AML) solutions added that any such change would likely incur significant short-term costs related to model validation, system changes, and retraining. The consensus is that while the industry watches these developments closely, the path forward is one of careful analysis and communication to ensure perceptions align with reality.
Does Raising Thresholds Really Modernize BSA?
The intent of BSA reporting requirements is to pass intelligence to law enforcement for use in their investigations. It seems counterintuitive to reduce the information passed on to law enforcement with a change to reporting thresholds that is unlikely to benefit BSA programs. The idea of increasing thresholds due to inflation carries little weight when one considers that the use of cash has been significantly reduced due to the ease and ubiquity of peer-to-peer transactions and payment cards. It seems less likely that a business, much less an individual, would be performing large cash transactions today than when the CTR and SAR requirements were first implemented.
Concerns were raised that an increased threshold could lead to new challenges, such as monitoring for structuring at a new, higher dollar amount, and that investigations would simply shift from “structuring” to “excessive cash” without a meaningful reduction in workload. It was noted that the general public may not be made aware of an increase in the CTR threshold, and some customers could continue to structure transactions to avoid exceeding $10,000. Other customers aware of the change would do the same at the new $30,000 threshold. An overzealous examiner or auditor could assert that the apparent intent to structure at either level is reportable, causing more work and confusion for both banks and law enforcement.
Navigating Change with Confidence
While the Streamline Act may appear to promise efficiency through reduced filing volumes, the reality for BSA leaders is far more complex. Threshold changes could introduce short-term costs, require system updates, and demand careful communication to manage executive expectations. At Nasdaq Verafin, we understand these challenges and are committed to helping institutions navigate regulatory change with confidence.
About the Author:
CHUCK TAYLOR
CAMS, CAFP, Head of AML Commercial Strategy, Nasdaq Verafin
Chuck serves as the subject matter expert on AML regulations, industry trends, and best practices for financial crime prevention for Nasdaq Verafin. His role involves providing strategic insights to enhance the company’s financial crime solutions and assisting clients in navigating complex compliance requirements.
Prior to joining Nasdaq Verafin, Chuck served as Executive VP, Head of Financial Crimes Advisory (FCA) at AML RightSource. The FCA Practice at AML RightSource is a full-service advisory consultancy providing BSA Program support for all types of covered financial institutions.
Prior to Joining AML RightSource, Chuck was SVP and BSA Officer for City National Bank (CNB) a subsidiary of Royal Bank of Canada (RBC). Chuck had oversight responsibility for all aspects of the BSA function including maintenance of the Bank’s BSA program, BSA Risk Assessment, AML Transaction Monitoring, Currency and Suspicious Activity Reporting, Customer Identification Program, Sanctions filtering and BSA Training.
