IRS Launches New Strategy to Boost Financial Institution Collaboration and Combat Financial Crimes

Financial crimes — including tax evasion, money laundering, and fraud schemes —have become increasingly sophisticated, often crossing international borders and involving complex networks of transactions. To combat this, the Internal Revenue Service Criminal Investigation division (IRS-CI) is expanding its use of banking data and ramping up collaboration with financial institutions as it intensifies efforts to detect and prosecute financial crimes in a manner that fosters confidence in the tax system and compliance with the law.

In March of 2025, the IRS-CI released its updated Bank Secrecy Act (BSA) metrics, providing insight into the scale of its efforts. According to the report, between FY 2022 and FY 2024, 87.3% of criminal cases recommended for prosecution involved subjects with corresponding BSA filings. Of these cases, 97.3% resulted in a conviction, with an average prison sentence of 37 months. IRS-CI also identified $21.1 billion in fraudulent financial activity, seized $8.2 billion in criminal assets, and helped secure $1.4 billion in victim restitution over that period.

How the IRS Uses BSA Data

Under the BSA, financial institutions must file Suspicious Activity Reports (SARs) when they identify potentially unlawful activity. These reports form the foundation of IRS-CI’s efforts to investigate and build criminal cases, especially in matters involving money laundering and other related financial crimes.

New CI-FIRST Initiative

As part of its broader strategy, IRS-CI is introducing CI-FIRST (Feedback in Response to Strategic Threats)—a new engagement program designed to strengthen communication between IRS-CI and financial institutions. CI-FIRST aims to offer institutions transparency around how their SAR filings are used while also providing feedback to improve the effectiveness and precision of future reporting.

The program will also streamline subpoena processes and offer guidance on enhancing the effectiveness of suspicious activity reports. IRS-CI headquarters will engage directly with major financial institutions operating on a national and international scale. At the same time, regional field office personnel will coordinate with local banks, credit unions, and community-based financial institutions.

How Anchin Can Help

At Anchin, we work closely with our clients to navigate an increasingly complex regulatory environment. As IRS-CI intensifies its use of BSA data and formalizes partnerships through the CI-FIRST initiative, it’s more important than ever to ensure your internal compliance protocols are robust. Our professionals offer strategic guidance on enhancing Suspicious Activity Report (SAR) quality, managing regulatory risk, and preparing for increased information-sharing with enforcement agencies.

To explore how these developments may impact your financial structure or compliance strategy, contact Brian Sanvidge, CIG, CFE, Principal & Leader of Anchin’s Regulatory Compliance & Investigations Group, or your Anchin Relationship Partner.