WASHINGTON–In a move it said is designed to improve the SARs process, the Internal Revenue Service (IRS) has launched CI-FIRST (Feedback in Response to Strategic Threats), which it is describing as an IRS-CI initiative that will establish ongoing engagement with financial institutions.
“The program will ensure that financial institutions receive quantifiable results from IRS-CI on how the agency uses suspicious activity reports (SARs) to investigate federal crimes,” the IRS said in an announcement on its website. “As part of this program, IRS-CI will also streamline subpoena requests and share pointers with financial institutions on what to include in SARs to maximize impact. CI-FIRST will serve as an opportunity to address what’s working and what can be improved, creating continuous lines of communication between partners.

“IRS-CI headquarters will work with larger financial institutions that have a national and international presence, and field office personnel will work with regional and community banks and credit unions in their respective areas of responsibility,” the IRS continued.
A ’Major Barrier’
Added J. Edward Conway, executive secretary at the Wolfsberg Group, “The lack of constructive feedback on SARs has long been a major barrier to a more effective approach to disrupting criminal networks in the U.S. and abroad. CI-FIRST has the potential to drive higher quality information for law enforcement and a better distribution of resources in the fight against financial crime, demonstrating how feedback can be provided and incorporated at scale.”
Nearly One-Million Searches
According to the IRS, IRS-CI special agents ran an average of 966,900 searches annually against currency transaction reports during the last three fiscal years.
“Nearly 1,600 cases were opened in FY24 with at least one currency transaction report on the primary subject,” the IRS said. “The data also indicates that 67.4% of cases opened by IRS-CI had a subject with one of more currency transaction reports below $40,000, with 50% of currency transaction reports involving amounts less than $22,230.”
Stopping Narcotics Trafficking
The IRS said BSA data has also proven effective in helping IRS-CI combat narcotics trafficking and pandemic-era tax fraud.
“Since FY20, IRS-CI used BSA data to initiate nearly 1,300 investigations with ties to fentanyl and investigate alleged employee retention credit fraud totaling $5.5 billion,” the IRS added in its statement.
