AML/BSA and AI Agents: The Travel Rule, Transaction Monitoring, and SAR Filing
The Bank Secrecy Act has been around since 1970. FinCEN's expectations for AI-assisted transaction monitoring are not new — the 2021 guidance on AML program effectiveness explicitly called out model risk management and audit trail requirements for automated transaction monitoring systems.
If your AI agent initiates, approves, routes, or monitors financial transactions, AML/BSA requirements apply. There's no AI carve-out.
