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Law Enforcement Cases

This section of The SAR Activity Review affords law enforcement agencies the opportunity to summarize investigations where Suspicious Activity Reports (SARs), Currency Transaction Reports (CTRs) and other BSA information played an important role in the successful investigation and prosecution of criminal activity. This issue contains new case examples from Federal, State and local law enforcement agencies. Additional law enforcement cases can be found on the FinCEN website under the link to Investigations Assisted by BSA Data. This site is updated periodically with new cases of interest, which are listed by the type of form used in the investigation, type of financial institution involved and type of violation committed.

FinCEN appreciates the help of the many agencies that contributed to the cases in this issue. In many cases, SAR confidentiality requirements preclude FinCEN from associating the name of all law enforcement agencies and entities that utilized SAR information for specific cases highlighted in The SAR Activity Review.

In this edition of The SAR Activity Review, we take a special look at structuring cases. The first five examples are cases that started with proactive reviews from SAR review teams. The filing institutions noted the subjects conducted activity that indicated attempts to evade currency reporting requirements. When law enforcement began investigating the subjects of the SARs, they found underlying crimes that included mortgage fraud, tax evasion, and possible medical fraud.

Our sixth case reminds us of the role that BSA data can play in narcotics investigations. Congress passed the Bank Secrecy Act (BSA) in 1970, in part, as a response to drug traffickers using the financial system to launder their ill-gotten gains. Prior to the BSA, drug traffickers could walk into a bank, casino, or financial institution with bags of cash and conduct transactions, including converting the currency to a single check or transmitting the funds around the globe, with anonymity. As this case example illustrates, drug traffickers still try to get around the reporting requirements and launder illicit currency through casinos, car dealerships, and financial institutions.

Finally, we also include excerpts from two press releases that illustrate the importance of anti-money laundering statutes in combating sophisticated crime. While not every criminal case involves the use of BSA data, the lack of BSA filings is often telling in itself. In both instances reported here, purportedly legitimate businessmen facilitated money laundering by willfully disregarding BSA statutes.

Contributing editors: Shawn Braszo, John Summers, Jennifer White, James Emery and Jack Cunniff.

Excerpted from SAR Activity Review Issue 16, page 31

First published on 10/01/2009

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