SAR leak

Posted By: edAudit

SAR leak - 10/17/18 08:07 PM

https://www.foxnews.com/politics/treasur...icials-russians
Posted By: BrianC

Re: SAR leak - 10/17/18 08:26 PM

Good board training fodder for when they ask the BSA Officer, "Why don't you give us the names of the SAR filings."
Posted By: Elwood P. Dowd

Re: SAR leak - 10/17/18 08:28 PM

Dozens of articles, all appearing within the last 4 hours.

Seriously depressing... frown
Posted By: MHuff

Re: SAR leak - 10/17/18 08:45 PM

This is absolutely infuriating!!
Posted By: HappyGilmore

Re: SAR leak - 10/17/18 08:50 PM

i am glad they are pursuing this. if banks can't rely on the confidentiality of these reports, they will stop filing them...or at least think long and hard about each one filed...
Posted By: Richard Insley

Re: SAR leak - 10/17/18 10:37 PM

Originally Posted By Sugar Coater
This is absolutely infuriating!!
+1
Posted By: Richard Insley

Re: SAR leak - 10/17/18 10:39 PM

Originally Posted By HappyGilmore
banks...will...think long and hard about each one filed...
They damned-well should have done that for each and every SAR they ever filed.
Posted By: edAudit

Re: SAR leak - 10/18/18 11:08 AM

My issue is that the SAR's are being filed for suspicious activity which on at least on some are being filed on some really bad individuals. (international terrorist, Various Gangs, international governmental agency's ) and the potential of violence against the person that notified the government about the illegal activity.

A five year, $250,000 fine for the leaker is no where enough.
Posted By: Elwood P. Dowd

Re: SAR leak - 10/18/18 11:34 AM

Criminal complaint
Posted By: Richard Insley

Re: SAR leak - 10/18/18 11:56 AM

Originally Posted By edAudit
A five year, $250,000 fine for the leaker is no where enough.

The complaint alleges there were 541 messages between Edwards and the reporter. If it's proven that each message illegally transmitted SARs or related information, would that mean she could be facing 541 X 5 yrs = 2,705 yrs. in federal prison? That sounds much better!
Posted By: edAudit

Re: SAR leak - 10/18/18 12:17 PM

2,705 yrs sounds about right.

I had heard that she was only going to be charged with 2 counts and with a plea...
Posted By: edAudit

Re: SAR leak - 10/18/18 12:24 PM

next issue if she was not authorized to be able to save the SAR's on an external drive why did she have access? I am authorized and have a daily need yet in my place I still need each item approved.
Posted By: John Burnett

Re: SAR leak - 10/18/18 02:11 PM

A careful read of the complaint reveals some of the ways in which the FBI and FinCEN were able to show what was compromised and how. Worthy of a spy novel. And that there is an unnamed Associate Director at FinCEN suspected of also communicating hundreds of times last year with the same unnamed reporter. An amazing amount of information in those 18 pages of the complaint.
Posted By: HappyGilmore

Re: SAR leak - 10/18/18 02:16 PM

Originally Posted By Richard Insley
Originally Posted By HappyGilmore
banks...will...think long and hard about each one filed...
They damned-well should have done that for each and every SAR they ever filed.


i won't disagree with that...but we also both know about the prevalence of defensive filings when there is no need, and many a regulator insisting on filing ones where the level of activity doesn't even come close to being worthy under threat of negative report from the regulators...
Posted By: edAudit

Re: SAR leak - 10/18/18 03:11 PM

And that there is an unnamed Associate Director at FinCEN suspected of also communicating hundreds of times last year with the same unnamed reporter.


Just asking and do not expect an answer

why unnamed and why not prosecuted to the fullest
Posted By: Richard Insley

Re: SAR leak - 10/18/18 03:22 PM

Originally Posted By HappyGilmore
we also both know about...regulator insisting...under threat of negative report...
...and now there is a specific objection to these heavy-handed "recommendations."

This is much more than a crime--a trust has been broken. Banks and the rest of the financial services industry were betrayed. We were promised...decade after decade...that this information would be guarded against public release.
Posted By: BuckDog

Re: SAR leak - 10/18/18 03:28 PM

So much for "secrecy". Five years is not enough and whoever is the Associate Director needs to be named and charged. As well as the reporter. I think my file for "non filed" SARs will get bigger with a lot of documentation for not filing. Maybe the main reason will be for "risk of retaliation" from the subject due to the risk of the SAR being disclosed. ....... ( Hands in Face).
Posted By: HappyGilmore

Re: SAR leak - 10/18/18 03:36 PM

i will be very surprised if any jail time is actually served, i'm betting suspended sentence and probation...just my opinion
Posted By: edAudit

Re: SAR leak - 10/18/18 04:06 PM

not file log

Although customer is a know Mob hit man, $100,000. cash deposit we will not result in a file due to last SAR filed on this customer resulted in an job opening due to death of employee who filed.
Posted By: pabankerone

Re: SAR leak - 10/18/18 05:56 PM

Does this DOJ press release really disclose the names of the suspects? While the name of the reporter "Reporter -1" and "News Organization-1" are not included?


https://www.justice.gov/usao-sdny/pr/sen...disclosing-sars

"The illegally disclosed SARs pertained to, among other things, Paul Manafort, Richard Gates, the Russian Embassy, Mariia Butina, and Prevezon Alexander."
Posted By: John Burnett

Re: SAR leak - 10/18/18 06:58 PM

They aren't pursuing the reporter or his employer because of the free press implications, so they are not named. Note that there's another FinCEN personality designated as CC-1 (co-conspirator) who is unnamed (and so far, unindicted) except for identification as an Associate Director of FinCEN. Does anyone not think the proverbial poop is going to hit the fan at FinCEN? I wonder what the Twitterverse will have to say about this?
Posted By: pabankerone

Re: SAR leak - 10/18/18 07:16 PM

I understand the free press implications, but why would they release the names of the subjects/suspects? Doesn't that in itself violate the confidentiality of the SAR?
Posted By: John Burnett

Re: SAR leak - 10/18/18 07:20 PM

I'd agree with you except for the "cat's out of the bag" or "horse is out of the barn" (take your choice) situation.
Posted By: SMQ, CRCM

Re: SAR leak - 10/18/18 07:35 PM

Why protect the "Reporter" and "News Organization"? Even if they are not going to prosecute, why not say who benefited. Let the light shine on the pond scum.

Might still be building the case against co-conspirator, so I will wait to discuss this one.
Posted By: Buddy the Elf

Re: SAR leak - 10/18/18 07:38 PM

It's very easy to find the News Organization and reporter. Just google the titles of the articles as they are in the complaint.
Posted By: John Burnett

Re: SAR leak - 10/18/18 07:46 PM

This topic is certainly creating a lot of "buzz."
Posted By: SMQ, CRCM

Re: SAR leak - 10/18/18 07:47 PM

This????
https://www.buzzfeednews.com/article/jas...inance-election
Posted By: Elwood P. Dowd

Re: SAR leak - 10/18/18 08:21 PM

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.
Posted By: Richard Insley

Re: SAR leak - 10/18/18 08:34 PM

Buzzfeed's not the problem here--it's the deep-state criminals who decided to release the SARs to unauthorized recipients.
Posted By: John Burnett

Re: SAR leak - 10/18/18 08:39 PM

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.
Posted By: Andy_Z

Re: SAR leak - 10/18/18 08:45 PM

Some might say the fox was guarding the hen house. There needs to be severe penalties or the system itself is compromised from within.
Posted By: Richard Insley

Re: SAR leak - 10/18/18 09:47 PM

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.
Posted By: HappyGilmore

Re: SAR leak - 10/19/18 01:33 PM

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.
Posted By: Richard Insley

Re: SAR leak - 10/19/18 03:55 PM

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.
Posted By: HappyGilmore

Re: SAR leak - 10/19/18 04:25 PM

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
Posted By: Elwood P. Dowd

Re: SAR leak - 10/22/18 11:30 AM

Article more reflective of an industry perspective.
Posted By: Elwood P. Dowd

Re: SAR leak - 10/25/18 07:16 PM

Article
Posted By: HappyGilmore

Re: SAR leak - 10/26/18 01:13 PM

ooh, claiming whistleblower status...certainly adds a new wrinkle
Posted By: Elwood P. Dowd

Re: SAR leak - 10/26/18 01:42 PM

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...
Posted By: edAudit

Re: SAR leak - 10/26/18 02:00 PM

https://home.treasury.gov/footer/prohibited-personnel-practices-and-whistleblower-protection

Nope nothing about sending SAR info to the media
Posted By: rainman

Re: SAR leak - 10/26/18 03:43 PM

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.