CI-FIRST: How IRS-CI Is Empowering Law Enforcement

ARTICLE: June 2025

CI-FIRST: How IRS-CI is Empowering Law Enforcement

As financial crime evolves in scope and complexity, effective investigations require more than just solid leads, they require strong partnerships. That’s the driving force behind CI-FIRST, a new initiative from IRS Criminal Investigation (IRS-CI) designed to maximize the value of Suspicious Activity Reports (SARs) by improving collaboration between law enforcement and the financial sector.

Here’s what CI-FIRST means for investigators on the front lines.

What Is CI-FIRST?

CI-FIRST stands for Criminal Investigation: Feedback In Response to Strategic Threats.

Launched by IRS-CI in March this year, this program provides financial institutions with measurable feedback on how their SARs are being used in real criminal cases. It’s a step toward more tactical intelligence sharing, helping improve the quality of SARs while making law enforcement’s job more efficient.

Why It Matters

The value of a well-filed SAR can’t be overstated. It can:

• Identify new targets.
• Uncover hidden assets.
• Support wiretap affidavits or search warrants.
• Strengthen the financial evidence in a criminal case.

But SARs are only as good as the data behind them, and that data is only useful if it’s actionable. That’s where CI-FIRST comes in. By closing the feedback loop, the IRS wants to help banks understand what types of SARs actually lead to outcomes like arrests, seizures, or prosecutions. That, in turn, improves the quality of reports received.

The Impact: The Value of Financial Intelligence

Recent IRS-CI results*:

• 87.3% of cases recommended for prosecution involved subjects with at least one SAR.
• 97.3% conviction rate in adjudicated cases.
• $21.1 billion in financial fraud identified.
• $8.2 billion in criminal assets seized.
• $1.4 billion in restitution ordered for victims.

These results show that financial institutions are submitting high-value SARs but there’s room to do even better, especially in emerging threat areas.

CI-FIRST in Practice

CI-FIRST is about making SARs more than just regulatory requirements – it’s about turning them into tools in real cases.

Key components include:

• Tactical feedback to filers on SARs that contribute to successful cases.
• Improved subpoena and data request protocols to reduce delays and friction.
• Focus on key threat areas like fentanyl trafficking, human smuggling, and cyber-enabled fraud.

For field agents and analysts, this means quicker access to relevant data, stronger intelligence from partners, and clearer pathways from SARs to investigations.

What You Can Do

If you’re a law enforcement officer or financial crimes investigator, here’s how you can leverage CI-FIRST:

• Encourage SAR feedback loops in your task force or agency collaborations.
• Integrate SARs earlier in your case development process.
• Coordinate with IRS-CI when targeting financial flows linked to high-risk crimes.
• Share case outcomes with IRS-CI to help inform ongoing SAR filer education.

In summary

CI-FIRST isn’t just an initiative. It’s a shift in how law enforcement and the financial sector work together. It’s about turning compliance reporting into a strategic intelligence pipeline, uncover, disrupt, and prosecute financial crime more effectively.

By aligning with financial institutions on strategic threats, CI-FIRST creates a force multiplier effect helping law enforcement move faster and build stronger cases that hold up in court.

*Source: IRS-CI releases FY24 BSA metrics, announces CI-FIRST initiative | Internal Revenue Service