The Senate has introduced the Streamlining Transaction Reporting and Ensuring Anti-Money Laundering Improvements for a New Era Act, or the STREAMLINE Act, an initiative led by Senate Banking Committee Chairman Tim Scott and Senator John Kennedy, with support from several Republican co-sponsors.

For the first time in over five decades, the bill would modernize key components of the Bank Secrecy Act (“BSA”). Some key proposed changes include: (1) increasing the reporting thresholds, (2) instituting periodic inflation adjustments, and (3) requiring Treasury to update and rationalize reporting processes and related form.  Industry groups, including the American Bankers Association and leading credit unions and community banking associations, have expressed support.

This article summarizes the bill’s core provisions that may impact banks, credit unions, money services businesses, and businesses that engage in large cash transactions.

Core Substantive Changes

The STREAMLINE Act targets three principal areas of the BSA framework: currency transaction reporting, suspicious activity reporting, and modernization of reporting forms and procedures.

Currency Transaction Report Threshold

First, the bill directs Treasury to raise the $10,000 threshold for Currency Transaction Reports (“CTRs”) to $30,000. (For a sense of scale, $10,000 in 2025 would be worth nearly $80,000 in 1970 dollars. Conversely, the $10,000 threshold today would have obligated financial institutions to report transactions – over the last 50 years – above about $1,200.) The CTR increase is designed to align reporting with contemporary economic realities and reduce low-value filings that have limited utility for law enforcement.

The bill further requires Treasury to adjust this figure every five years to reflect changes in the Consumer Price Index for All Urban Consumers, rounded to the nearest $1,000, with adjustments taking effect on the first January 1 following publication.

Suspicious Activity Report Threshold

Second, the bill raises thresholds applicable to Suspicious Activity Reports (“SARs”). Specifically, thresholds currently set at $2,000 would be raised to $3,000, and those at $5,000 would be raised to $10,000. The changes aim to reduce the volume of low-dollar SAR filings. This would enable financial institutions to prioritize higher-value (and perhaps higher-risk) activity and fund their AML programs more efficiently.

Non-Financial Firm Report Threshold

Third, the bill amends 31 U.S.C. § 5331 to raise from $10,000 to $30,000 the reporting threshold for the receipt of currency by persons engaged in a trade or business (i.e., nonfinancial businesses), with the same five-year CPI-based inflation indexing and effective date convention.

This change would materially impact high-cash nonfinancial sectors, such as bullion or currency businesses that currently complete Form 8300 filings for receipts over $10,000.

Reporting Forms and Procedures

The STREAMLINE Act mandates a Treasury-led review of forms and reporting and recordkeeping requirements under 31 U.S.C. §§ 5313, 5315, and 5318.

The bill directs Treasury to analyze aggregation, prioritization, and automation opportunities and to update forms and requirements as appropriate to improve effectiveness and efficiency in identifying illicit finance. The bill also requires Treasury to conduct and submit certain reports called for under the Anti-Money Laundering Act of 2020, indicating a broader push to harmonize and modernize the AML/CFT regime. Notably, the bill preserves Treasury’s authority to issue and maintain geographic targeting orders (“GTOs”).and, more broadly, to lower thresholds consistent with applicable law where risk warrants.

Timeline and Next Steps

The bill, as introduced, sets relatively aggressive agency timelines once enacted: 180 days for CTR and SAR regulatory updates and 360 days for Treasury’s broader form and process review. Actual implementation timelines will depend on the legislative process. If enacted, institutions should expect proposed rules and public comment periods before final regulations and effective dates.

McGuireWoods will continue to monitor developments and publish updates as this legislation proceeds. For questions about anti-money laundering compliance, including customer due diligence, program reviews, and filing obligations, contact the authors of this article or another member of the McGuireWoods’ Financial Services & Securities Enforcement, Government Investigations & White Collar Litigation, Healthcare, Tax & Employment Benefits, or Corporate & Private Equity teams.