The US Department of Treasury, Financial Crimes Enforcement Network, has issued its October 2007 “SAR Activity Review – Trends, Tips & Issues, which is a product of continuing dialogue and close collaboration among the nation’s financial institutions, law enforcement officials, and regulatory agencies to provide meaningful information about the preparation, use, and value of Suspicious Activity Report (SARs) filed by financial institutions.
[The Department is] continuing to provide expanded descriptions of law enforcement cases included in Section 3 to better demonstrate how important and valuable Bank Secrecy Act (BSA) data is to the law enforcement community. Many of these cases, which range in topic from high-yield investment schemes to international money laundering, were proactively initiated as a result of your BSA report filings. [They] are confident that the additional details provided in these cases will add more value for our readers. This edition addresses several noteworthy topics. The articles include perspectives on the BSA as it affects convenience checks and credit card cooperatives, including analytical reviews. An industry viewpoint addresses SAR reporting issues confronting the money services business industry. Finally, this issue contains guidance on definitions and criminal statutes for the SAR characterizations of suspicious activity.
The SAR Activity Review is possible only as a result of the extraordinary work of many FinCEN employees and FinCEN’s regulatory, law enforcement and industry partners. In order to recognize that hard work, we acknowledge contributors throughout the Review.
Below is a summary of topics addressed in this issue.
• Section 1: Director’s Forum;
• Section 2: Trends and Analysis – Trends in Suspicious Activity Reports Involving Convenience Checks; Use of the Category “Other” on Suspicious
Activity Reports; and Findings from Suspicious Activity Reports Referencing Credit Union Cooperatives;
1 Participants include, among others, the American Bankers Association; Independent Community Bankers of America; American Institute of Certified Public Accountants; Securities and Financial Markets Association; Non-Bank Funds Transmitters Group; Board of Governors of the Federal Reserve System; Office of the Comptroller of the Currency; Federal Deposit Insurance Corporation; Office of Thrift Supervision; National Credit Union Administration; U.S. Securities and Exchange Commission; U.S. Department of Justice’s Criminal Division and Asset Forfeiture & Money Laundering Section and the Federal Bureau of Investigation; Drug Enforcement Administration; U.S. Department of Homeland Security’s Bureau of Immigration and Customs Enforcement and U.S.
Secret Service; U.S. Department of the Treasury’s Office of Terrorism and Financial Intelligence, Internal Revenue Service, and the Financial Crimes Enforcement Network.
• Section 3: Law Enforcement Cases – Investigations Assisted by Bank Secrecy Act Data;
• Section 4: Issues and Guidance – Definitions and Criminal Statutes for the Suspicious Activity Report Characterizations of Suspicious Activity;
• Section 5: Industry Forum – Suspicious Activity Reporting Issues Confronting the Money Services Business Industry; and
• Section 6: Feedback Form.”