...in light of the expertise, resources and focus of the IRS, the IRS should continue to perform the information processing and examination functions. The IRS has cultivated substantial anti-money laundering expertise over the years and contributed significantly to the administration of the BSA since its enactment in 1970. In recent years, the partnership forged by the IRS and FinCEN has been aimed at improving the administration of the BSA and prioritizing the challenges both agencies recognize need to be addressed... It would be both wasteful of resources and disruptive to the administration of the BSA to transfer these functions, especially since there is no other comparable agency with a similar combination of expertise and resources that could readily assume them.