When must a bank file a suspicious activity report under the Bank Secrecy Act?
A bank must file a suspicious activity report when it knows, suspects, or has reason to suspect a transaction of $5,000 or more involves funds from illegal activity, is designed to evade the BSA, or has no apparent lawful purpose.
The answer
The reporting trigger
31 CFR 1020.320 requires a bank to file a suspicious activity report for a transaction conducted or attempted by, at, or through the bank that involves or aggregates at least $5,000 in funds and that the bank knows, suspects, or has reason to suspect involves funds from illegal activity, is designed to evade the Bank Secrecy Act, has no apparent lawful purpose, or uses the bank to facilitate criminal activity.
The safe harbor
A bank that reports a suspicious transaction is protected from civil liability for the disclosure. Section 5318(g) of Title 31 bars any liability to any person under any law for the report or for failing to notify the subject of the report.
The judged input
What the AI drafted
Submitted to the judgeThis is an excerpt from a draft BSA/AML compliance memo — the kind of work product a lawyer generates with a legal-AI drafting tool, then has to stand behind. Kingsfield does not write it; it rules on the citations the model put in it. This draft cites three authorities; one of them is wrong.
The judge ruled on every citation as the draft used it — it accepted 31 CFR 1020.320 and 31 U.S.C. § 5318(g) and rejected 31 CFR 1010.311. Here is why.
The verdict
How Kingsfield ruled
Ruled 2026-06-23Each citation in the draft above was submitted to the Kingsfield judge and ruled against the primary-law corpus — Accept, Reject, or Inconclusive, per citation. These are live verdicts, not editorial. Each card shows the claim the draft made and the verbatim authority the verdict was rendered against.
The draft claimed: A bank must file a suspicious activity report for a transaction conducted or attempted by, at, or through the bank that involves or aggregates at least $5,000 in funds and that the bank knows, suspects, or has reason to suspect involves funds from illegal activity, is designed to evade the BSA, or has no apparent lawful purpose.
“General. (1) Every bank shall file with the Treasury Department, to the extent and in the manner required by this section, a report of any suspicious transaction relevant to a possible violation of law or regulation. A bank may also file with the Treasury Department by using the Suspicious Activity Report specified in paragraph (b)(1) of this section or…”
Cite found; proposition supported by the cited text.
The draft claimed: A financial institution that reports a suspicious transaction is shielded from liability to any person under any law for making the report or for failing to notify the person who is the subject of the report.
“§ 5318(g)(9) Information related to a report received by a financial institution from a foreign affiliate with respect to a suspicious transaction relevant to a possible violation of law or regulation shall be subject to the same confidentiality requirements provided under this subsection for a report of a suspicious transaction described in paragraph…”
Cite found; proposition supported by the cited text.
The draft claimed: Section 1010.311 sets the $5,000 threshold and the standard under which a bank must file a suspicious activity report for transactions involving suspected illegal funds.
Cite found, but the cited text does not support the claim. 31 CFR 1010.311 is the currency transaction report filing obligation for transactions in currency exceeding $10,000, not the suspicious activity report duty; the SAR obligation and its $5,000 threshold are at 31 CFR 1020.320. Regenerate with the correct authority.
Run your own work through the judge
Kingsfield rules on every citation, quote, and proposition your AI produces, against the primary law we cover. Accept, Reject, or Inconclusive, per citation, with a signed Audit Capsule.
Connect the Judge See the architectureThis page is legal information, not legal advice, and does not create an attorney-client relationship. The draft shown is an illustration of a typical AI answer; verdicts reflect the cited authority in the Kingsfield corpus as of the ruling date shown above.