FinCEN SAR Activity Review, Trends, Tips & Issues, Issue 10

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The SAR Activity Review Trends Tips & Issues Issue 10 Published under the auspices of the BSA Advisory Group May 2006
Table of Contents Introduction 1 Section 1 – Director’s Forum 3 Section 2 – Trends and Analysis Suspicious Activity Reports: Filing Activity and Detection of Unlicensed/Unregistered Money Services Businesses 5 Highlighted Trend: Mortgage Loan Fraud 13 Section 3 – Law Enforcement Cases Bank Secrecy Act Data is an Integral Component of the Federal Bureau of Investigation’s Geographic Information Mapping Technology 17 Investigations Assisted by Bank Secrecy Act Data 19 Section 4 – Tips on SAR Form Preparation & Filing Suspicious Activity Report Form Completion Tips – A Trend Analysis of Frequently Asked Questions Received on FinCEN’s Regulatory Helpline 33 Section 5 – Issues & Guidance Money Services Business Registration and De-Registration 39 Grand Jury Subpoenas and Suspicious Activity Reporting 42 When Does the 30-Day Time Period in Which to File a Suspicious Activity Report Begin? 44 Section 6 – Industry Forum Bank Secrecy Act Compliance by the Money Services Business Industry 47 Section 7 – Feedback Form 53 Appendix – Index of Topics from Current and Previous Editions of The SAR Activity Review – Trends, Tips & Issues
Page 4 and 5: Introduction The SAR Activity Revie
Page 6 and 7: Section 1 - Director’s Forum Iam
Page 8 and 9: Section 2 - Trends and Analysis Thi
Page 10 and 11: year period of January 1, 2002 thro
Page 12 and 13: Table 1: Types of Reported Activiti
Page 14 and 15: Informal Value Transfer Systems A t
Page 16 and 17: Additional guidance focusing on way
Page 18 and 19: Mortgage Fraud Hot Spots The Federa
Page 20 and 21: Section 3 - Law Enforcement Cases T
Page 22 and 23: Investigations Assisted by Bank Sec
Page 24 and 25: In the face of the evidence against
Page 26 and 27: and since 2000 was responsible for
Page 28 and 29: Suspicious Activity Reports Help Un
Page 30 and 31: transactions. In a period of approx
Page 32 and 33: Bank Secrecy Act Records Help Initi
Page 34 and 35: The BSA records retrieved included
Page 36 and 37: Section 4 - Tips on SAR Form Prepar
Page 38 and 39: 2. Questioning Individuals about Po
Page 40 and 41: Instead of being contacted by a per
Page 42 and 43: Section 5 - Issues & Guidance This
Page 44 and 45: • A business that is an MSB solel
Page 46 and 47: guidance about whether, when and ho
Page 48 and 49: Our suspicious activity reporting r
Page 50 and 51: Section 6 - Industry Forum In each
Page 52 and 53:
Agent MSBs file SARs based on subje
Page 54 and 55:
so general that their practicality
Page 56 and 57:
Section 7 - Feedback Form Financial
Page 58 and 59:
D. What information did you find le
Page 60 and 61:
Industry Forum: Check Fraud Loss Re
Page 62 and 63:
Law Enforcement Case: Drug Traffick
Page 64 and 65:
Law Enforcement Case: Structured De
Page 66 and 67:
SAR Tips: Instructions for Completi
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FinCEN SAR Activity Review, Trends, Tips & Issues, Issue 10

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