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Open Recommendations

Artificial Intelligence: Use and Oversight in Financial Services

GAO-25-107197
May 19, 2025
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1 Open Recommendations
Agency Affected Recommendation Status
National Credit Union Administration The Chair of NCUA should update the agency's model risk management guidance to encompass a broader variety of models used by credit unions and provide additional details on key aspects of effective model risk management. (Recommendation 1)
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When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Nonbank Mortgage Companies: Greater Ginnie Mae Involvement in Interagency Exercises Could Enhance Crisis Planning

GAO-25-107862
Jan 31, 2025
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1 Open Recommendations
Agency Affected Recommendation Status
Government National Mortgage Association (Ginnie Mae) The President of Ginnie Mae should develop processes for participating in interagency exercises—taking into consideration the potential risks and benefits of sharing nonpublic information in a crisis—and for incorporating lessons learned from the exercises into Ginnie Mae's issuer default strategy. (Recommendation 1)
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When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Illicit Finance: Treasury Should Monitor Partnerships and Trusts for Future Risks

GAO-25-106955
Dec 19, 2024
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1 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN periodically analyzes SAR data for the risk of illicit activity related to trusts and partnerships and incorporates this analysis in future money laundering and terrorist financing risk assessments. (Recommendation 1)
Open
When we confirm what actions the agency has taken in response to this recommendation, we will provide updated information.

Currency Transaction Reports: Improvements Could Reduce Filer Burden While Still Providing Useful Information to Law Enforcement

GAO-25-106500
Dec 11, 2024
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4 Open Recommendations
Agency Affected Recommendation Status
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to eliminate CTR data fields that are unnecessarily burdensome for filers and of little use to law enforcement. This could be done as part of FinCEN's AMLA review or through a different method. (Recommendation 1)
Open
In a June 2025 letter, FinCEN reiterated its agreement with this recommendation and noted that it is conducting the necessary analysis and consultations to achieve the recommendation's objectives as part of its report under section 6204 of the Anti-Money Laundering Act of 2020. In response to GAO's September 2025 inquiry on the status of the recommendation, FinCEN officials referenced the FinCEN Director's recent testimony on related topics. The written statement explained that FinCEN is in the process of exploring changes to CTR reporting requirements, including improving CTR forms. To fully implement this recommendation, FinCEN would need to update the form to reduce unnecessarily burdensome fields of little use to law enforcement. Identifying and eliminating such fields could reduce unnecessary filer burden while still providing highly useful information to law enforcement.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to simplify and clarify aggregation requirements. This could be done as part of FinCEN's AMLA review or through a different method. (Recommendation 2)
Open
In a June 2025 letter, FinCEN reiterated its agreement with this recommendation to simplify and clarify aggregation requirements. FinCEN also stated that it is conducting the necessary analysis and consultations to achieve the recommendation's objectives as part of its reports under sections 6204 and 6205 of the Anti-Money Laundering Act of 2020. Those provisions called on FinCEN to review reporting requirements for CTRs, including thresholds and aggregation requirements, and propose changes to reduce any unnecessarily burdensome regulatory requirements. To fully implement this recommendation, FinCEN would need to take steps to simplify and clarify aggregation requirements. Simplifying and clarifying these requirements could make CTR compliance easier and less burdensome.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN establishes a performance management process that defines performance goals and measures for monitoring the usefulness of CTRs. (Recommendation 3)
Open
FinCEN reiterated its agreement with this recommendation in a June 2025 letter. According to the letter, although FinCEN considers CTRs to be included in an existing performance measure as part of improving tracking of overall BSA data, FinCEN is exploring the possibility of supplementing its performance measures process to include a survey on the usefulness of CTRs. The letter notes that FinCEN has begun work on a contract for a potential new survey on the usefulness of CTRs. To fully implement this recommendation, FinCEN would need to establish related performance goals and measures specific to the usefulness of CTRs, which would enable FinCEN to better assess the effectiveness of CTRs in achieving statutory objectives and identify areas for enhancement.
Department of the Treasury The Secretary of the Treasury should ensure that the Director of FinCEN takes steps to reduce the number of CTRs filed that are not used by law enforcement, such as by raising the reporting threshold or expanding criteria to allow for further exemptions. These actions should be informed by an analysis of the characteristics of CTRs that have been less likely to be accessed by law enforcement. (Recommendation 4)
Open
FinCEN reiterated its agreement with this recommendation in a June 2025 letter, including that actions to reduce the number of CTRs should be informed by an analysis of the characteristics of CTRs that have been less likely to be accessed by law enforcement. According to the letter, FinCEN is conducting the necessary analysis and consultations to achieve the recommendation's objectives as part of its reports under section 6204 and 6205 of the Anti-Money Laundering Act of 2020. To fully implement this recommendation, FinCEN would need to conduct the aforementioned analysis to determine steps to reduce the number of unused CTRs. By taking steps to reduce the number of unused CTRs, such as by raising the reporting threshold or expanding exemptions, FinCEN has opportunities to reduce reporting burdens without compromising the value of CTRs to law enforcement.

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