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Pre-Launch · Filing seed · Series A — Q4 2026

Bank Secrecy Act · 31 USC 5311 et seq.

The statutory backbone of the AML program.

The Bank Secrecy Act is the oldest and most foundational anti- money-laundering statute in the United States. As a Money Services Business registered with FinCEN and as a future Alternative Trading System, Wavestar is subject to the BSA record-keeping, reporting, and program requirements at 31 CFR Chapter X. This page describes the filing obligations and the record-retention standards we maintain.
Statute
31 USC 5311 et seq.
Regulations
31 CFR Chapter X
FinCEN E-File
BSA E-Filing System
Program owner
Chief Compliance Officer

Reporting obligations

Four filings. Strict timelines.

Covered institutions file four principal forms with FinCEN. Each has a defined threshold, a defined timeline, and a required retention period. Wavestar's controls are calibrated so every reportable event is filed within the statutory window.

Filing matrix

Suspicious Activity Report (SAR)
FinCEN Form 111 · filed within 30 calendar days of detection, extended to 60 days where the subject is not yet identified

Required for any transaction conducted or attempted, aggregating USD 2,000+ (MSB threshold), that the institution suspects derives from illegal activity, is intended to evade the BSA, or has no apparent lawful purpose.

Currency Transaction Report (CTR)
FinCEN Form 112 · filed within 15 calendar days of the transaction

Required for currency transactions by, through, or to the institution exceeding USD 10,000 in a single business day, including aggregated related transactions.

Foreign Bank and Financial Accounts (FBAR)
FinCEN Form 114 · filed by 15 April with extension to 15 October

Filed where the institution has signature authority over, or financial interest in, foreign financial accounts aggregating USD 10,000+ at any point in the calendar year.

Report of International Transportation of Currency
FinCEN Form 105 · filed on the date of transport

Applies to physical transport of currency or monetary instruments exceeding USD 10,000 across the US border. Not expected to apply to Wavestar operationally.

Record retention

Five years. Accessible. Audit-ready.

31 CFR 1010.430 requires covered institutions to retain BSA records for at least five years. Wavestar retains the full record set for five years past the end of the member relationship in a WORM-protected archive with documented access controls.
  • 01

    CIP and CDD records

    All identity documents collected, methods used to verify, any sanctions and PEP screening results, risk ratings assigned, and refresh history. Retained five years past relationship end.
  • 02

    Beneficial ownership

    BOI records collected under 31 CFR 1010.230 and 1010.380, including ownership documentation, control determinations, and refresh history. Retained five years past relationship end.
  • 03

    SAR files

    Every SAR filed, the underlying facts, the decision memo, and the supporting transactional data. Also retained: SAR decisions NOT to file, with the documented rationale. Five years from filing date.
  • 04

    CTR files

    All CTRs filed, aggregation documentation, and supporting transactional records. Five years from filing date.
  • 05

    Wire transfer records

    All wire transfers of USD 3,000+ through any rail retain originator and beneficiary records under 31 CFR 1010.410, including Travel Rule data. Five years.
  • 06

    Training and program records

    Policies, procedures, training curricula, attendance records, independent review reports, and board reporting. Retained for the life of the program plus five years.

Travel Rule

Beneficial counterparty data travels with the value.

The BSA Travel Rule (31 CFR 1010.410(f)) requires covered financial institutions to transmit identifying information on the originator and beneficiary with any transfer of funds of USD 3,000 or more. FinCEN's Joint Statement of 11 May 2019 extends the rule to Convertible Virtual Currency transfers by MSBs. Wavestar's settlement rails — Fedwire, SWIFT, domestic ACH, USDC on Ethereum and Base — all include the Travel Rule fields at and above the applicable threshold. Digital-asset transfers use the IVMS 101 data model through an interoperable Travel Rule messaging layer.

Travel Rule fields · every transfer USD 3,000+

Originator name
Legal name of the sending member
Originator account
Wavestar account identifier or external account reference
Originator address
Registered address of the sending member
Beneficiary name
Legal name of the receiving member
Beneficiary account
Wavestar account identifier or external reference
Amount and currency
Transfer amount in native denomination
Execution date
ISO 8601 UTC timestamp
Payment purpose
Settlement of trade · free-text purpose code

Program governance

Independent. Tested. Reported.

BSA enquiry

Questions about our reporting cadence or record-keeping?

Counterparty diligence teams and regulatory reviewers can request the current BSA program manual and the most recent independent-review summary under NDA.

Request the program manualRead the AML program