Which customer scenario is least likely to trigger BSA reporting requirements?

• A. A customer with simple cash transactions under reporting thresholds
• B. A customer with complex, high-risk transactions
• C. A customer conducting international wire transfers
• D. A customer making suspicious cash deposits above threshold

Answer: (C)

Under the BSA, reporting is driven by cash activity and indicators of suspicious behavior. Currency Transaction Reports are filed for cash transactions that exceed a set threshold, and Suspicious Activity Reports are filed when there are red flags suggesting illicit activity. An international wire transfer, by itself and when legitimate and well-documented, does not automatically generate a BSA report. The transfer is regulated under the travel rule, which requires banks to share certain information about the originator and beneficiary, but this information sharing is not the same as filing a FinCEN CTR or SAR. So a normal, properly documented international wire transfer is less likely to trigger a BSA report than scenarios that involve large cash deposits or clearly high-risk or suspicious activity. In contrast, a customer making suspicious cash deposits above threshold or engaging in complex, high-risk transactions would be more likely to prompt SAR activity, and those under threshold cash transactions could still trigger reporting if they appear in a suspicious pattern.