BSA: What Happens to Those SARs?
A common gripe of financial institutions is that they maintain compliance programs and file CTRs and SARs but don't see results. The complaint is usually that they haven't heard anything about that SAR they filed six months ago. Is anyone looking? The answer to that question is an emphatic YES!
The law enforcement agencies charged with BSA responsibilities were well represented at ABA's Money Laundering Enforcement Conference. All of them stressed that SARs and CTRs are invaluable to their work. And although it isn't visible to the public's eye, a great deal of work is going on.
G. Clayton Grigg, Unit Chief, Terrorist Financial Operations Section, FBI, stated that BSA data, both CTRs and SARs, is used in all aspects of FBI investigations. Law enforcement is using a new approach which makes the data reported by financial institutions significantly more powerful. Working with FinCEN, the FBI can merge information that has been classified and firewalled with the data reported on CTRs and SARs.
The merged databases mean that investigators can pull and sort information by specific trackers or identifiers such as telephone numbers, social security numbers, and addresses. In fact, the names mentioned in SAR narratives can be included in this data search. The data analysis identifies items in common and enables investigators to find accounts they didn't know about before.
Now they are conducting studies to find more uses of the BSA reports. One such project involves looking at what case agents knew about possible cases before the reports were filed and how much is actually triggered by the reports themselves.
Of all the BSA reports filed, CTRs and SARs from financial institutions are the most powerful. Of the substantive hits leading to investigations, 41% came from CTR data and 38% came from SAR data.
What all this means is that you should think about each filing as becoming a part of a database. Some individual filings will lead to a direct contact from law enforcement. But the real power of the reports comes to life when combined with other reports.
Copyright © 2005 Compliance Action. Originally appeared in Compliance Action, Vol. 10, No. 13, 11/05
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