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#2195879 - 10/18/18 07:46 PM Re: SAR leak edAudit
John Burnett Offline
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This topic is certainly creating a lot of "buzz."
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#2195880 - 10/18/18 07:47 PM Re: SAR leak edAudit
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Between the lines
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#2195890 - 10/18/18 08:21 PM Re: SAR leak John Burnett
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Based on its specific wording, the prohibition against SAR disclosures applies to banks, government entities and their employees, no one else. The person who sent me a copy of the "Spitzer SAR" a few years ago did not fit into any of those categories. He did not break the law.

"Buzzfeed" did not break the law by disclosing the SARs' existence and content.
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#2195895 - 10/18/18 08:34 PM Re: SAR leak edAudit
Richard Insley Offline
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Buzzfeed's not the problem here--it's the deep-state criminals who decided to release the SARs to unauthorized recipients.
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#2195899 - 10/18/18 08:39 PM Re: SAR leak edAudit
John Burnett Offline
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We are working our way toward political discussion here. Let's avoid that territory, please. I may have stepped too far in my mention of the Twitterverse.
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#2195900 - 10/18/18 08:45 PM Re: SAR leak edAudit
Andy_Z Offline
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Some might say the fox was guarding the hen house. There needs to be severe penalties or the system itself is compromised from within.
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#2195911 - 10/18/18 09:47 PM Re: SAR leak Andy_Z
Richard Insley Offline
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Originally Posted By Andy Z
the system itself is compromised from within.
If these charges are true, that has already happened. Next, we move on to ask what other secret information will appear in another publication when one or more rogue federal employees have an axe to grind with we the people.
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#2195941 - 10/19/18 01:33 PM Re: SAR leak edAudit
HappyGilmore Offline
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Pulling people out of the ditc...
let's not kid ourselves here, there are people leaking information from every level of government, across every public body. you can read many an article where the source is listed as "a government official who shall remain anonymous because they are not authorized to comment." Generally, no one on this site cares about those, because really, who cares about the cost of rubber and how it will affect the price of tires.

But...

Now that this leaking of information is tied to our specific industry, it becomes a problem. Suddenly, we need to stop this leaking of information! Welcome to the digital age, where no information can be secured.
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#2195962 - 10/19/18 03:55 PM Re: SAR leak HappyGilmore
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I'm not naive...I'm furious. Year after year, government agents and agency officials told me (and many other BOLers)...face to face...that the SAR information was and is secure, and that we should have no reluctance to submit SARs--even in marginal cases. We trusted them and the system they represented. Now, it's morning...and I don't feel the respect.

I, for one, really care whenever there's good reason to believe a government employee has violated the terms of his/her employment and committed crimes. Some will argue that there are victimless crimes (who cares about butter, guns, rubber, or tires?), but illegal leaks of confidential information (true, false, or merely suspected) about individual citizens can (and do) ruin their lives.

Nothing is sudden or industry-specific in my concern about criminal activity that can destroy people. If there is no way to secure information, then we, as a nation, should reconsider collecting it in the first place.
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#2195968 - 10/19/18 04:25 PM Re: SAR leak Richard Insley
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Pulling people out of the ditc...
Originally Posted By Richard Insley
If there is no way to secure information, then we, as a nation, should reconsider collecting it in the first place.


as long as there is more than 1 person involved in collection or storage, it can never truly be secure
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#2196040 - 10/22/18 11:30 AM Re: SAR leak HappyGilmore
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Article more reflective of an industry perspective.
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#2196493 - 10/25/18 07:16 PM Re: SAR leak Elwood P. Dowd
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#2196539 - 10/26/18 01:13 PM Re: SAR leak edAudit
HappyGilmore Offline
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Pulling people out of the ditc...
ooh, claiming whistleblower status...certainly adds a new wrinkle
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#2196541 - 10/26/18 01:42 PM Re: SAR leak HappyGilmore
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FinCEN employees receive annual training on the Whistleblower Protection Act, what it applies to, what it doesn't. This is an attempt to grasp at straws...
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#2196544 - 10/26/18 02:00 PM Re: SAR leak edAudit
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#2196565 - 10/26/18 03:43 PM Re: SAR leak HappyGilmore
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Originally Posted By HappyGilmore
Originally Posted By Richard Insley
If there is no way to secure information, then we, as a nation, should reconsider collecting it in the first place.


as long as there is more than 1 person involved in collection or storage, it can never truly be secure


Exactly. Richard, I agree with your outrage and I'm sure all those officials who made (and still make) those promises are very sincere. But if you started a thread for people to contribute stories of SAR filings with compromised secrecy, it would get pretty long pretty quick. The Spitzer case was an example, but it only was publicized because it was Spitzer. Government officials are no more perfect than the rest of us.

FinCEN sends SARs to a variety of federal law enforcement groups. And when FIs provide copies of SARs to local law enforcement, the circle gets even wider. It is only human nature that there are going to be disclosures (purposeful or neglectful). This is an outrageous and egregious case. But the systemic risk will always be there no matter how secure the systems are. It is a price that we pay for Congress's decision to deputize financial institutions as intelligence gathering agents for the war on tax evasion drug smuggling terrorism election interference.
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