Business Accused of Structuring

Immigration and Customs Enforcement conducted an investigation based on a number of Suspicious Activity Reports involving a licensed money services business. The owners and operators of the money services business conspired with unlicensed money remitters (couriers) to commit criminal acts. The couriers brought large sums of cash to the business that were subsequently deposited into the business?s bank accounts and then wired to the Middle East.

The investigation revealed that the money services business had a very limited number of clients, yet made many millions of dollars in cash deposits within a two-year period. The money services business?s owners failed to file

Currency Transaction Reports for cash deposits made by their clients and prepared fraudulent records to evade the filing requirements.

Immigration and Customs Enforcement served a number of arrest and search warrants, as well as conducted subsequent consensual searches, and seized nearly $200,000. (Source: Immigration and Customs Enforcement)

Suspicious Activity Report Leads to Conviction of Chief Executive

A Suspicious Activity Report filed by a financial institution led to a bank fraud investigation by the Federal Bureau of Investigation and the Federal Deposit Insurance Corporation?s Office of Inspector General. The Suspicious Activity Report implicated a loan secretary in the misapplication of several million dollars. The resulting investigation uncovered insider abuses reaching to the chief executive officer, who was subsequently charged and ultimately pleaded guilty to assisting customers who were close friends in evading lending limits by allowing them to receive a series of loans in the names of family members and/or business associates. The chief executive officer also protected certain customers from Federal Deposit Insurance Corporation regulatory scrutiny by misapplying funds to clear overdrafts in their business accounts. The actions of these insiders contributed to the failure of the institution. The investigation has resulted in four convictions so far, including that of the chief executive officer. (Source: Federal Bureau of Investigation)

Excerpted from SAR Activity Review Issue 9, page 32