The CI-FIRST initiative represents a shift in financial crime prevention, establishing collaboration between federal agencies and financial institutions through enhanced SARs transparency and feedback mechanisms
Key insights:
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Auditors are critical in initial financial crime detection — Professionals responsible for auditing transactions are the primary line of defense in identifying suspicious activity, such as irregular deposits or transactions inconsistent with an account’s purpose.
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CI-FIRST enhances SAR effectiveness and collaboration — The new CI-FIRST initiative by IRS Criminal Investigation marks a significant shift by providing financial institutions with feedback on SARs, fostering a more transparent and collaborative partnership with federal agencies.
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Financial crimes are evolving, requiring improved SAR quality — Recent trends show a troubling rise in sophisticated financial crimes like account takeover fraud, elder exploitation, and resilient check fraud, underscoring the urgent need for enhanced clarity and improved quality in SARs preparation.
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The financial professionals responsible for auditing transactions are integral to the detection of financial crimes. These individuals serve as the initial point of contact for identifying transactions that may be cause for concern, including patterns such as irregular recurring deposits or activity inconsistent with the account’s intended purpose.
Upon detection of potentially suspicious financial activity, a bank initiates a thorough internal review to assess whether the circumstances warrant the submission of a Suspicious Activity Report (SAR). If the criteria for suspicion are met, the SAR is filed electronically with the Financial Crimes Enforcement Network (FinCEN) within 30 to 60 days. The report is housed in a secure government database, accessible to authorized agencies such as the FBI, DEA, and IRS for further analysis. While this reporting mechanism plays a vital role in combating financial crime, it is not without limitations.
A significant challenge of the SARs system historically has been the absence of feedback provided reporting to banks regarding the outcomes of their submissions, resulting in a unilateral flow of information. To address this issue, the IRS Criminal Investigation launched a new initiative known as Feedback in Response to Strategic Threats (CI-FIRST).
The CI-FIRST initiative
In early 2025, the CI-FIRST initiative was introduced, aiming to establish a transparent and effective partnership between federal agencies and private financial institutions. This program enhances transparency around SARs filings, providing financial institutions with clearer insight into how their submitted SARs are utilized in federal investigations. By doing so, it marks a significant shift in the way SARs are handled.
CI-FIRST fosters a more collaborative relationship between financial institutions and federal investigators, allowing for direct feedback and communication. This open dialogue could lead to more efficient and effective SARs processes. Moreover, the program has the potential to be a blueprint for other agencies, demonstrating a successful model for improving data quality and facilitating more robust information sharing. The success of CI-FIRST could have far-reaching implications for the way financial crimes are investigated.
Within this fraud landscape, several troubling patterns emerged that underscore the sophistication and persistence of financial criminals. For example, check fraud has demonstrated resilience despite the digital age, with financial institutions filing 682,276 SARs related to this traditional form of fraud, representing a notable uptick from previous periods.
CI-FIRST fosters a more collaborative relationship between financial institutions and federal investigators, allowing for direct feedback and communication.
Even more alarming was the dramatic 36% surge in account takeover fraud, a cybercrime that reflects criminals’ increasing ability to exploit digital vulnerabilities and compromise customer accounts. This surge resulted in nearly 178,000 reports, underscoring how criminals are adapting their methods to target online banking and other digital financial services.
The SARs data also revealed that identity theft remained a persistent threat, comprising more than one-quarter of all fraud-related SARs filed in 2024. This substantial proportion demonstrates how personal information breaches continue to fuel criminal enterprises across multiple fraud categories. Perhaps most concerning from a societal perspective was nearly 10% increase in elder financial exploitation cases compared to 2023, with 171,233 SARs filed specifically addressing crimes against vulnerable older adults. This trend reflects not only the increasing targeting of seniors but also potentially improved recognition and reporting of these crimes by financial institutions.
Financial institutions face mounting challenges
These comprehensive trends collectively illustrate the mounting challenges facing financial institutions, law enforcement, and regulatory bodies in their efforts to prevent, detect, and prosecute financial crimes. The sheer volume and diversity of criminal activity captured in these SAR statistics demonstrate that traditional approaches to combating financial crime require enhancement and modernization.
It is within this context that the CI-FIRST initiative emerges as a particularly relevant and timely response. One of the initiative’s most significant contributions lies in its commitment to providing enhanced clarity and guidance on the preparation of required SARs reports.
This improvement in clarity serves multiple critical functions in the financial crime prevention ecosystem. For example, by establishing clearer standards and expectations for SAR preparation, the initiative aims to improve the quality and consistency of the information provided to law enforcement agencies and regulatory bodies.
The sheer volume and diversity of criminal activity captured in these SAR statistics demonstrate that traditional approaches to combating financial crime require enhancement and modernization.
Further, the enhanced clarity in SARs preparation has direct implications for the speed and effectiveness of subsequent law enforcement actions. When SARs contain more precise, complete, and well-organized information, investigators can more quickly identify patterns, establish connections between cases, and build stronger foundations for legal action. This improved information quality significantly accelerates the process of obtaining subpoenas, as law enforcement officials can present more compelling and comprehensive evidence to judicial authorities when requesting these critical investigative tools.
Finally, the enhanced SARs preparation standards contribute directly to more effective prosecutions of individuals engaged in financial crimes. Prosecutors rely heavily on the detailed information contained in SARs to build their cases, and when this information is clearer, more thorough, and better organized, it becomes significantly easier to demonstrate criminal intent, establish patterns of illicit behavior, and present compelling evidence to juries. This improvement in the foundational documentation makes it substantially more likely that prosecutions will be both accurate in targeting genuine criminal activity and successful in securing convictions.
The expediency gained through these improvements creates a virtuous cycle in financial crime prevention. Faster, more successful prosecutions serve as stronger deterrents to potential criminals while also providing more rapid justice for victims. Additionally, enhanced efficiency allows law enforcement resources to be deployed more effectively across a broader range of cases, potentially addressing the growing volume of financial crimes reflected in the 2024 SAR statistics.
You can find more of our coverage of SARs and related efforts to combat financial crimes here
