I don’t understand why this issue hasn’t made its way to the Supreme Court by now. There is no way it can be constitutional.
As for the SAR’s that banks must submit, the process is unyielding. There is no discretion allowed on the part of the bank, at least for non-too-big-to-fail banks. Some of the big boys got caught a couple years back knowingly laundering money for the drug cartels and they got a slap on the wrist is all. If small banks did that they’d lose their charter. I am on the board of a small bank and each month the President is required to inform us if the bank has filed any SAR’s. Sometimes he knows that the transaction is completely legit but he has no choice in the matter and the SAR gets filed. The Feds never tell the bank what they do with any given SAR.