Details on SARs Filed by Credit Union Cooperatives
Several facts about the 78 depository institution SARs and 10 SAR-MSBs with cooperative narrative references appear noteworthy. One SAR-MSB identified an elaborate plot to launder stolen funds using shared branches to deposit cash into a digital currency account holder?s credit union account. Sixty-two of the 78 (79.49%) depository institution SARs and five of the ten (50%) SARMSBs identified credit union account holders as subjects. Thirty-nine of the 78 (50%) depository institution SARs alleged that a credit union account holder was attempting to launder funds. Eight of the ten SAR-MSBs involved money laundering as well.
Twenty-seven of the 78 (34.62%) depository institution SAR filings with narrative references to the credit union cooperatives involved transactions occurring at multiple shared-branching locations. Twenty-two of these 78 (28.21%) named members of participating credit unions as subjects. Fourteen SARs involving multiple shared branches contained narrative references to money laundering or structuring. Thirteen filings involving multiple shared branches had narrative references to frauds or attempted frauds.
Queries produced 23 depository institution SARs filed from June 2, 2004 through March 6, 2007 by the credit union cooperatives covered in this study. The reports had a total of 16 unique filer-name variations, 10 unique FEINs, and 17 unique combinations of the two.
At least 65.21 percent of SARs filed by credit union cooperatives contained other potential data quality problems. Approximately 30.43 percent of the total filings had either blank or incomplete narrative fields. Some filers attempted to place narratives in the Violation Type Other field. Some reports contained the wrong Branch Address, wrong Total dollar amount involved in known or suspicious activity, or lacked FEINs. Other filers inserted ?please see attached? in the SAR narrative and listed Armed Robbery as the characterization of suspicious activity. As a reminder, when SAR forms are received at the Enterprise Computing Center- Detroit, only information that is in an explicit, narrative format is entered into the system; thus, tables, spreadsheets or other attachments are not entered into the SAR System database.
Table 1 displays the different characterizations of suspicious activity found in the 23 depository institution SAR filings (some reports contained multiple characterizations).
Explanations of the covered cooperative depository institution SAR filings with ?Other? as the characterization of suspicious activity included the following:
- ?Armed Robbery?
- ?Money Order Fraud?
- ?Rejected Wire OFAC List?
- ?OFAC Hit?
- ?Avoid Filling Out CTR?
- ?4 Separate Cash Deposits?
- ?Deposited 9000 00 Cash In Acct He Holds?
- ?Made Two Cash Deposits To An Account He?
Excerpted from SAR Activity Review Issue 12, page
First published on 10/01/2007