Suspicious Activity Reports by Money Services Businesses

FinCEN?s analysis of SAR narratives filed by money services businesses (MSBs) using the designated insurance search terms identified 341 records.

Exhibit 2 depicts the location and total volume of MSB SARs by the top eleven states where these reports were filed.

Exhibit 2


Money Services Business SAR Narrative Sampling
A sample of 259 MSB SAR narratives identified the following activities:

• Forty-nine percent of SARs filed reported the suspicious use of money orders that were made payable to insurance companies. The purchase of these money orders appeared to have been structured in order to avoid BSA reporting requirements.
• SARs also reported the use of official checks that were made payable to insurance companies. Fifteen percent of the SARs filed reported the structured purchase of official checks.
• A small number of SAR filings reported the receipt of multiple transactions on the same day at the same agent location. These transactions appeared to involve structuring.

Excerpted from SAR Activity Review Issue 11, page 20