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BOL SAR Research Guide

The requirement to detect and report suspicious activity presents enormous challenges. To help, FinCEN began publishing the SAR Activity Review in 2000. The editions published in the ensuing years embody a rich collection of tips, case studies, and guidance on specific issues. Researching them, however, takes time and perseverance, and sometimes what you need is a quick insight, a fast answer. For that reason, we've developed our own research guide to the SAR Activity Review. Starting with FinCEN's own index, we've massaged and tweaked and come up with a user-friendly way to link you to just what you need.



TOPIC Issue Date Excerpt Link
Suspicious Activity - Info/Trends/Stats by type
Advanced Fee Schemes Aug. 2002
Analysis of Suspicious Activity Report Oct. 2009
Assessment of SARs Filed by the Securities and Futures Industry May 2009
Computer Intrusion Oct. 2001
Computer Intrusion Violations Within Depository Institutions Oct. 2005
Consumer Loan Fraud Aug. 2004
Convenience Checks Oct. 2007
Coupon Redemption Fraud Nov. 2003
Credit/Debit Card Fraud Aug. 2002
Credit Union Cooperative Shared-Branching Model Oct. 2007
Credit Union Cooperative - Synopsis of SAR Filing Activity Oct. 2007
Credit Union Cooperative - SAR Details Oct. 2007
Depository Institution Filing Oct. 2007
Depository Institution SARs with CU Coop Narrative References Oct. 2007
Food Stamp Fraud Using Electronic Benefit Transfer Cards Aug. 2004
Identity Theft Jun. 2001
The Insurance Industry: A Study of Suspicious Activity Reports May 2007
The Insurance Industry: An Assessment of Suspicious Activity Report Filings May 2008
More on Identity Theft Oct. 2001
Life Insurance: SAR Analysis – Indications of Suspicious Activity Feb. 2003
Money Laundering and Structuring Violations Aug. 2004
Money Laundering in the Residential Real Estate Industry: An Assessment Based Upon SAR Filing Analysis May 2008
Money Transmitter Activity Jun. 2001
Money Transmitters may be Money Laundering Vehicle Oct. 2001
Mortgage Loan Fraud Jun. 2006
Mortgage Loan Fraud: Update of Trends Based Upon An Analysis of SARs May 2008
Mortgage Loan Fraud: SAR Filings Oct. 2009
On-line and/or Internet Banking Nov. 2003
Pre-paid Telephone Cards Jun. 2001
Refund Anticipation Loan (RAL) Fraud Aug. 2004
SARs Filed on Unregistered/Unlicensed MSBs Jun. 2006
SARs Filed by Institutions Using the Depository Institution Form May 2007
SAR Narrative Analysis - Depository Institutions Oct. 2007
SAR Narrative Analysis - Other Institutions Oct. 2007
SAR Narrative - Money Services Businesses Oct. 2007
SAR Quality Considerations May 2009
SEC Enforcement Actions for Failure to File May 2009
Use of the Category "Other" on Suspicious Activity Reports Oct. 2007
SEC Enforcement Actions for Failure to File May 2009
SEC’s Use of SARs Filed by Firms May 2009
Suspicious Activity Trends with MSBs May 2007
Suspicious Activity Reports in the Securities Industry May 2009
Suspicious Activity Reports by Money Services Businesses May 2007
Suspicious Activity Report by the Securities and Futures Industries May 2007
Suspicious Activity Reviews by Securities Regulators May 2009
Suspicious Automated Teller Machine (ATM) Activity Oct. 2000
Use of Traveler’s Checks to Disguise Identities Oct. 2001
(Also see Terrorism/Terrorist Financing Below)
SAR Completion Tips
Avoiding Common Errors in SARs Oct. 2009
Computer Intrusion and Frequently Asked Questions Oct. 2001
Filing a Corrected or Amended SAR Aug. 2002
Filing a SAR for Ongoing or Supplemental Information Aug. 2002
Frequently Asked Questions Received on FinCEN's Regulatory Helpline Apr. 2005
How do I . . .? Aug. 2004
Identity Theft and Pretext Calling Oct. 2001
Identifying the Category, Character & Subjects of SARS Oct. 2009
Importance of Accurate and Complete Narratives Feb. 2003
Importance of the Narrative Jun. 2001
Improvements to Eliminate Reporting Deficiencies Nov. 2003
Informal Value Transfer System--Special SAR Form Completion Guidance Feb. 2003
Insignificant Suspicious Activity Report Filing Errors Oct. 2005
Instructions for Completing the SAR Form Nov. 2003
Law Enforcement Suggestions When Preparing SARs Oct. 2009
Problems with Taxpayer Identification Numbers Oct. 2005
SAR Filing Tips for MSBs Aug. 2002
SAR Filing Tips - Trend Analysis of FAQs Received on FinCEN’s Regulatory Helpline June 2006
SAR Form Completion When Reporting Identity Theft May 2009
SAR Form Completion Tips— A Trend Analysis of Frequently Asked Questions Received on FinCEN’s Regulatory Helpline May 2007
SAR Form Completion Rate-National Overview Oct. 2000
SAR Form Preparation and Filing Oct. 2000
SAR Forms: Where to Send Completed SAR Forms Feb. 2003
SAR Forms: Where to Send Completed SAR Forms Nov. 2003
SAR Guidance Package Aug. 2004
Special Guidance Related to Identity Theft and Pretext Calling Jun. 2001
Suspicious Activity at a Location Other than the Institution Oct. 2005
Suspicious Activity Reporting Guidance for Casinos Aug. 2004
Terrorist-Related Activity: How to report potential terrorist-related activity Nov. 2003
Terrorist-Related Activity: How to report potential terrorist-related activity Feb. 2003
Terrorist-Related Activity: How to report potential terrorist-related activity Aug. 2002
Tips from the Regulators Nov. 2003
SAR Filing Guidance
FinCEN’s BSA E-Filing System:Trends & BenefitsOct. 2009
FinCEN & Regulatory Agencies Debunk SAR Quotas Myth Aug. 2004
Global Resolution of Potential Enforcement Actions May 2009
John Byrne on SAR Quotas Aug. 2004
IRS Computing Center/FinCEN Help Line & Website Nov. 2003
FAQs from FinCEN Help Line – 314a Process Nov. 2003
MSB SAR Reporting Questions Nov. 2003
Filing SARs on Activity Outside the United States Jun. 2001
Filing SARs on Continuing Activity after Law Enforcement Contact Jun. 2001
Filing SARs on OFAC List or 314(a) Matches Nov. 2003
Filing SARs & the beginning of the 30-Day Time Period June 2006
Financial Institutions Hotline Oct. 2001
National Security Letters prompting SAR filings Apr. 2005
Repeated SAR Filings on Same Activity Oct. 2000
SAR Clock - Date of "Initial Detection" & the 30-Days Oct. 2008
SAR Guidelines for Introducing and Clearing Broker Dealers May 2009
SAR Guidelines for Reporting Advance Fee Schemes Aug. 2004
SAR Guidelines for Grand Jury Subpoenas June 2006
Suspicious Activity Reports: Not Just for Law Enforcement June 2006
Timing for SAR filings Oct. 2000
Voluntary SAR Filings Oct. 2001
Voluntary SAR Filings - more guidance Jun. 2001
Disclosing SARs
CTRs & SARs: Reading With Context May 2008
Disclosure of SAR Documentation Jun. 2001
Disclosure of SARs and Underlying Suspicious Activity Oct. 2000
Prohibition on Notification Jun. 2001
Providing Suspicious Activity Reports to Appropriate Law Enforcement Oct. 2005
SAR Rulings: SAR Disclosure Feb. 2003
SAR Disclosure as part of Civil Litigation Aug. 2002
Florida Appeal Court Decision re: SAR production Nov. 2003
Guidance as to What to do When Asked for Production of SARs Aug. 2004
Prohibition on Notification Jun. 2001
Providing Suspicious Activity Reports to Appropriate Law Enforcement Oct. 2005
SAR Rulings: SAR Disclosure Feb. 2003
SAR Disclosure as part of Civil Litigation Aug. 2002
Disclosing in response to National Security Letters Apr. 2005
Subpoenas for Electronic Records By the FBI May 2008
MSB Issues/Guidance
Questions and Answers on MSBs Jun. 2001
MSB SAR Reporting Questions Nov. 2003
Money Services Businesses: SARs filed by MSBs Aug. 2002
Money Services Businesses: Registration and De-Registration June 2006
SARs filed by Money Services Business Feb. 2003
SARs filed on Unregistered/Unlicensed MSBs Jun. 2006
Safe Harbor Issues
Applicability of Safe Harbor Oct. 2001
Applicability of Safe Harbor Jun. 2001
Safe Harbor Protection for Employment References Aug. 2002
OFAC and FATF
OFAC (but see revised guidance in next item) Aug. 2002
OFAC - Revised Guidance on filing SARs Apr. 2005
Non-Cooperative Countries and Territories Nov. 2003
Non-Cooperative Countries and Territories Oct. 2001
Non-Cooperative Countries and Territories Jun. 2001
Non-Cooperative Countries and Territories Oct. 2000
Training
An Overview of Suspicious Activity Report Training Elements Apr. 2005
PACS
PATRIOT Act Communications System Feb. 2003
Expansion of PACS Nov. 2003
314(a) Information Requests
314(a) Information Requests under the USA PATRIOT Act Feb. 2003
314(a) Results Enhance Material Support for Terrorism Case Aug. 2004
FAQs from FinCEN Help Line – 314a Process Nov. 2003
Filing SARs on OFAC List or 314(a) Matches Nov. 2003
Section 314(a) USA PATRIOT Act Progress Report (February 2003 – October 2003) Nov. 2003
Section 314(a) USA PATRIOT Act Progress Update (February 2003 – May 2004) Aug. 2004
Examples of Cases
$1.8 Million Hidden in House Oct. 2009
314(a) Results Enhance Material Support for Terrorism Case Aug. 2004
Attorney and Three Accomplices Convicted in Multi-Million Dollar Real Estate Fraud Aug. 2004
Attorney Sentenced in Fraud Case Oct. 2005
Auto Dealership Pleads Guilty to Structuring Cash Deposit Oct. 2007
Black Market Peso Exchange Jun. 2001
Black Market Peso Exchange Used to Launder Drug Proceeds May 2007
Bank Failure Investigation Oct. 2005
Bank Manager Steals Hundreds of Thousands of Dollars May 2007
Bank President Guilty in Loan Fraud Aug. 2004
Bankruptcy Bust-out Scheme Nov. 2003
Bankruptcy Fraud Involving Family Members Nov. 2003
BSA Data Leads to $18 Million Seizure Aug. 2004
BSA Data Leads to Drug Trafficker Identification May 2007
Business Accused of Structuring Oct. 2005
"Cash Back" Mortgage Fraud Scheme May 2009
Certificate of Deposit Fraud Scheme May 2009
Charity Evades Reporting Requirement Apr. 2005
Check Cashing Business Oct. 2001
Check Kiting Suspect Jun. 2001
Check Kiters Cost Banks Millions of Dollars May 2007
Cocaine Trafficker Jun. 2001
Cocaine Trafficker Oct. 2009
Computer Chip Theft Ring Oct. 2001
Conspiracy & Money Laundering Oct. 2008
Convicted Felon Not Complying with Restitution Order May 2008
Conviction of Pharmacist Feb. 2003
Conviction of Chief Executive Oct. 2005
Counterfeit Check Fraud Oct. 2000
Credit Credit Fraud & ID Theft by Illegal Alien with Ties to Organized Crime Oct 2007
Credit Card Theft Jun. 2001
Criminal Organization – Baby Formula Oct. 2000
Customs Fraud Oct. 2000
Drug Gang Money Laundering Methods May 2008
Drug Money Laundering Oct. 2000
Drug Money Laundering Oct. 2000
Money Laundering Cases in the News Oct. 2009
Drug Trafficker Forfeits Structured Cash Aug. 2004
Drug Traffickers Laundering Profits Through Casinos June 2006
Drug Trafficking and Money Laundering Jun. 2001
Drug Trafficking Ring & International Wire Transfers May 2008
Edible Delicacies Land Man in Prison Oct. 2005
Elected Official Convicted of Bankruptcy Fraud & Structuring Oct. 2007
Embargo Investigation Jun. 2001
Embezzlement Oct. 2000
Extortion and Title 31 Oct. 2001
Food Bank Theft Oct. 2000
Forgery of U.S. Treasury Checks Nov. 2003
Former Banker Sentenced for Avoiding IRS Reporting Aug. 2002
Former Executive in Prison for Tax Evasion Oct. 2005
Fraudulent Banking Scheme June 2006
Gambling Addicted Bank Officer Steals from Bank May 2007
Gift Shop Operating as an Unregistered MSB Oct 2008
Hawala Investigation Nov. 2003
Hawala Operation Apr. 2005
Hedge Fund Fraud Case May 2009
High Yield Investment Program Scheme May 2009
Identity Thief Receives Nearly 4 Years in Prison Oct. 2005
Illegal Activities by Liquor Stores May 2007
Illegal Casa de Cambio Oct. 2001
Illegal Check Cashing Scheme Oct. 2007
Illegal Money Transfers to Iran Feb. 2003
Illegal Money Transfers to Iran by Iranian Regime Supporter May 2007
Illegal Money Transfers to Iraq Aug. 2002
Illegal Internet Pharmacy Oct. 2008
Illegal Online Pharmacy & Money Laundering May 2008
Importance of SAR Reporting to Law Enforcement Investigations Oct. 2001
Individual Operating as Unlicensed Money Transmitter Aug. 2004
Immigration Violations & Money Laundering May 2008
Insider Fraud Contributes to Bank Failure Apr. 2005
Insurance Fraud Restitution June 2006
Insurance Executive Embezzled to Pay Gambling Debts May 2007
Insurance Executive Embezzled from Local Government's Self-Insured Health Fund Aug. 2004
Internal Fraud at Local Bank Feb. 2003
International Fraud Ring May 2008
International Lottery Scheme Oct. 2007
International Money Laundering Via Stored Value Cards Oct. 2007
International Money Laundering Case Aug. 2002
Investment Firm CEO Feb. 2003
Investment Fraud Scheme Nov. 2003
Investment Fraud Scheme Oct. 2000
Investment Scam Oct. 2001
Law Enforcement Cases Oct. 2009
Life Insurance Investment Vehicles Scam May 2009
Marijuana Farm Owner Sentenced Apr. 2005
Marijuana Traffickers Wash, Dry, & Iron "Dirty" Currency Oct 2008
Medical Fraud Oct. 2008
Medicare Fraud & Money Laundering May 2008
Medicaid Fraud Oct. 2000
Metal Traders Charged in International Bank Fraud Scheme Aug. 2002
Methamphetamine Production Ring Oct. 2001
Money Laundering and Pyramid Scheme Apr. 2005
Money Laundering by RV Dealer Oct. 2001
Money Laundering in Maryland Aug. 2002
Money Laundering involving Insurance Industry Feb. 2003
Money Laundering involving Iraq Nov. 2003
Money Laundering of Marijuana Sales Proceeds Nov. 2003
Money Laundering Scheme Transferred over $12 Million to South American Countries Oct. 2005
Money Launderer Organized Retail Theft Oct. 2008
Money Remitter Sending Money to Iraq Feb. 2003
Money Remitter Structuring Transaction May 08
Money Remitting Business Laundering Drug Proceeds Apr. 2005
Mortgage Broker Convicted of Structuring Oct. 2008
Mortgage Elimination Scheme May 2007
Mortgage Fraud Scheme Oct. 2007
Mortgage Fraud Scheme May 2009
Mortgage-Related Ponzi Scheme Oct. 2008
Natural Resources Ponzi Scheme May 2009
Nigerian Advance Fee Scam Nov. 2003
Nigerian Round-Tripping Investigation Aug. 2004
Nigerian Wire Transfer Fraud Oct. 2007
Non-Profit Organization Operating as Money Remitter Aug. 2004
Operation Cheque Mate Oct. 2005
Operation Mule Train Oct. 2000
Organized Crime Network Oct. 2000
Owner of Service Company Sentenced in Tax Evasion Scheme Oct. 2005
Phantom Bank Scheme Jun. 2001
Ponzi Scheme Jun. 2001
Ponzi Scheme Aug. 2004
Ponzi Scheme June 2006
Ponzi Scheme Oct. 2007
Racketeering Scheme Involving Organized Crime & Trash Collectors May 2007
Securities Conversion Scheme Oct. 2008
Securities Dealer Jun. 2001
Serial Mortgage Fraud Offender Oct. 2009
Sports Betting Ring Oct. 2001
Sports Card Theft Oct. 2001
Stock Fraud Oct. 2000
Stolen Check Ring Oct. 2001
Stolen Check Scheme Jun. 2001
Structuring to Avoid BSA Reporting Requirements Oct. 2009
Structured Deposits Exceeding $700,000 Aug. 2004
Structuring and Food Stamp Fraud Aug. 2002
Structuring by Doctor Oct. 2009
Structuring by Mortgage BrokerOct. 2009
Structuring by Three Family Members Aug. 2002
Structuring by Two Businesses May 2007
Structuring by Restaurant Owner Oct. 2008
Suspect Sentenced to Five Years in Prison & Ordered to Pay $1 Million in Restitution Oct. 2005
Tax Evasion Case Aug. 2002
Tax Evasion by a Business Owner Apr. 2005
Tax Fraud Conspiracy Oct. 2008
Tax Fraud Investigation May 2008
Telemarketing Fraud Aug. 2004
Terrorism Investigation Apr. 2005
Travel Agent Jun. 2001
Unlicensed Money Remitter ($10 million in assets frozen) June 2006
Unlicensed Money Remitter ($1.2 million) Nov. 2003
Unlicensed Money Remitter ($3 million) Feb. 2003
Unlicensed Money Remitter ($427,000) Feb. 2003
Unlicensed Money Transmission Scheme Aug. 2002
Unlicensed South American Money Exchanger Aug. 2004
Worker’s Compensation Fraud Oct. 2000
State and Local Law Enforcement Use of SAR Data Aug. 2004
State and Local Law Enforcement Use of SAR Data Nov. 2003
State and Local Law Enforcement Use of SAR Data Aug. 2002
State and Local Law Enforcement Use of SAR Data Oct. 2001
Miscellaneous
Update: Auditing the AML Program – What’s New? Oct. 2009
BSA Data - Component of FBI’s Geographic Information Mapping Technology June 2006
Cessation of Relationship/Closure of Account Oct. 2000
Correspondent Accounts and Shell Company Activity Jun. 2001
Shell Company Activity Oct. 2000
Some Tips for Auditing the Suspicious Activity Reporting Program Nov. 2003
FACTA May Warrant Further Analysis of ID Theft by FinCEN Oct. 2008
FinCEN’s Financial Institutions Hotline Aug. 2002
Talk back to FinCEN! Nov. 2003
USA PATRIOT Act: Section 311 Authority Feb. 2003
Mailbag – Questions from the Industry Oct. 2001
Terrorism/Terrorist Financing
Coupon Redemption Fraud Nov. 2003
Hawalas Feb. 2003
Informal Value Transfer Systems Feb. 2003
Informal Value Transfer Systems – Update Nov. 2003
Non-Profit Organizations Feb. 2003
SAR Filers Identify Suspicious Monetary Instruments Clearing Through International Cash Letters Nov. 2003
Aspects of Financial Transactions that May Indicate Terrorist Financing Aug. 2002
Financial Action Task Force (FATF) Efforts Aug. 2002
FinCEN Analysis of SAR Filings and other BSA information Aug. 2002
Reconstruction of Hijacker’s Financial Activities Aug. 2002
Terrorism and Terrorist Financing Nov. 2003
Terrorist Financing filed on SARs Apr. 2005
SARs Filed Referring to Terrorism (Prior to 09/11/2001 & 09/11/2001 through 03/31/2002) Aug. 2002
SARs Filed that Refer to Terrorism (March –September 2002) Feb. 2003
Reports/Trends/Statistics
ATM Commonly Filed Violations Aug. 2004
BSA Data Profiles: Feedback from State Regulators Oct. 2008
BSA Data: Nebraska Department of Banking and Finance Oct. 2008
BSA Data Assists Oklahoma in MSB Licensing Oct. 2008
By the Numbers Update, Issue 6, a BOL recap. Jun. 2006
Check Fraud Loss Report - 2000 Oct. 2000
Check Fraud Loss Report - 2003 Feb. 2003
Section 314(a) USA PATRIOT Act Progress Report (February 2003 – October 2003) Nov. 2003
Section 314(a) USA PATRIOT Act Progress Update (February 2003 – May 2004) Aug. 2004
Multilateral Illicit Currency Flows Study Jun. 2001
Percentage of SARs Reporting Structuring Oct. 2001
Regional Money Remitter Activity Oct. 2000
Role of SARs in High Risk Money Laundering and Related Financial Crime Areas Oct. 2000
Reports of Solicitation Letters (Advanced Fee Fraud or 4-1-9 Scams) Oct. 2001
Russian Criminal Activity Oct. 2000
SAR Data Assists IRS in MSB Registration Oct. 2008
SARs Valuable in FDIC Oversight Oct. 2008
International Issues
Global Use of SARs Jun. 2001
Increased SAR Reporting Involving Mexico Oct. 2000
Indicators of Misuse of Informal Value Transfer Systems Feb. 2003
Use of U.S.-Based Shell Corporations and Foreign Shell Banks by Eastern Europeans to Move Money Aug. 2004
Suspicious Endorsed/Third-Party Checks Negotiated Abroad Aug. 2004
Suspicious Activity Involving the Iraqi Dinar Apr. 2005
Industries Other than Banking
Automobile Retail Industry Feb. 2003
Boat/Yacht Retail Industry Feb. 2003
Broker-Dealer SARs – The First Year Aug. 2004
Casino and Card Club Industries Apr. 2005
Pawn Brokers: SAR Analysis – Indications of Suspicious Activity Feb. 2003
Real Estate Industry – Sales and Management SARS Nov. 2003
Expansion of SAR and AML Compliance Requirements to New Industries Aug. 2002
Further Expansion of SAR Requirements to New Industries Feb. 2003
Financial Industries Required to File SARs Nov. 2003
Suspicious Activity Reported by Casinos Oct. 2000
SARs filed by Money Services Business Feb. 2003
Suspicious Activity Reports for Securities and Futures Industries Oct. 2005
Securities Industry: SAR Analysis – Indications of Suspicious Activity Feb. 2003
Securities and Futures Industries SARs: The First Quarter Nov. 2003
Securities Firms and the PATRIOT Act Oct. 2005
Travel Industry: SAR Analysis -- Indications of Suspicious Activity Feb. 2003



If you need to read individual issues of the SAR Activity Review, you'll find direct links to the FinCEN documents below.
Issues of the SAR Activity Review
Issue 16, October 2009
Issue 15, May 2009
Issue 14, October 2008
Issue 13, May 2008
Issue 12, October 2007
Issue 11, May 2007
Issue 10, May 2006
Issue 9, October 2005
Issue 8, April 2005
Issue 7, August 2004
Issue 6, November 2003
Issue 5, February 2003
Issue 4, August 2002
Issue 3, October 2001
Issue 2, June 2001
Issue 1, October 2000

First published on BankersOnline.com 1/13/06







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