IRS-CI uses bank filings in nearly all criminal investigations

The Internal Revenue Service's Criminal Investigation unit is leveraging the data it receives from financial institutions under the Bank Secrecy Act for the vast majority of its probes, according to new figures released Tuesday.

The newly released fiscal year 2025 metrics indicate that 94% of IRS-CI cases were searched against BSA data in FY25, resulting in over 3.9 million searches of BSA filings. Nearly 89% of IRS-CI cases had BSA filings tied to the subject of the investigation, while 11.7% originated directly from a BSA filing.

For tax-related investigations, from FY23-FY25, IRS-CI investigated 1,394 cases of refund fraud with the alleged fraud totaling $2.9 billion. 99% of these cases had BSA filings associated with the primary subject. In addition, IRS-CI opened 1,006 employment tax evasion cases during this same timeframe, with alleged fraud totaling $1.4 billion. Nearly two-third (63%) of these investigations had a BSA filing associated with the primary subject.

"BSA data is often the first signal that something isn't right," said IRS-CI Chief Guy Ficco in a statement Tuesday. "These filings become essential puzzle pieces in identifying patterns, following financial trails and building cases that protect taxpayers."

Visualization created with AI assistance based on original reporting.

Nearly 80% of IRS-CI investigations had primary subjects associated with suspicious activity reports and 66.8% had primary subjects associated with currency transaction reports.

Financial institutions file a CTR when a cash transaction totals more than $10,000 or an aggregated CTR when a customer makes multiple cash transactions totaling over $10,000 in a single business day, even if the transactions occur at different times, locations, or accounts. In FY25, nearly half of the investigations IRS-CI opened had a primary subject with a CTR under $20,000. The median cash-in and cash-out dollar amounts for CTRs used in IRS-CI investigations ranged between $12,000 to $12,543.

From FY23-FY25, IRS-CI cases using BSA filings resulted in a 98% conviction rate and average prison sentences of 42 months, over $450 million in asset forfeitures, and nearly $500 million in restitution for crime victims.

The latest figures show an increasing trend toward use of BSA data to investigate tax crimes and obtain conviction. Last year, IRS-CI reported that from fiscal years 2022 through 2024, 87.3% of IRS-CI's criminal investigations recommended for prosecution had a primary subject with a related BSA filing, and adjudicated cases led to a 97.3% conviction rate, with defendants receiving average prison sentences of 37 months. IRS-CI also leveraged BSA data to identify $21.1 billion in fraud linked to tax and financial crimes, seize $8.2 billion in assets tied to criminal activity, and obtain $1.4 billion in restitution for crime victims.

Last year, IRS-CI also embarked on a new initiative for requesting financial records from banks to track illegal activity such as money laundering, teaming up with the American Bankers Association and the Treasury Department's Financial Crimes Enforcement Network to present the Optimizing Financial Records Request initiative to banking executives. 

In March 2025, IRS-CI announced CI-FIRST (Feedback in Response to Strategic Threats), a public-private partnership to modernize how IRS-CI works with financial institutions by delivering feedback on BSA reporting to financial institutions, facilitate knowledge exchange through CI-FIRST forums and FinTAX crime alerts, and strengthen coordination to disrupt and combat financial crime. IRS-CI's Optimizing Financial Records Requests initiative, also known as OFRR, aims to accelerate investigative timelines by streamlining and standardizing how IRS-CI requests and how financial institutions respond to legal order and subpoena requests.