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

Introduction
The SAR Activity Review – Trends, Tips & Issues is a product of
continuing dialogue and close collaboration among the nation’s financial
institutions, law enforcement officials, and regulatory agencies1 to provide
meaningful information about the preparation, use, and value of Suspicious
Activity Reports (SARs) filed by financial institutions.
In response to your feedback, we have expanded the descriptions of law
enforcement cases included in Section 3 to better demonstrate how integral
Bank Secrecy Act (BSA) data is to the law enforcement community. As you
will read, many of these cases, which range in topic from drug investigations
to insurance fraud, were proactively initiated as a result of your BSA report
filings. We are confident that the additional details provided in these cases
will add more value for our readers.
This edition’s theme is the role of SARs in the Money Services Business (MSB)
industry. The articles in this issue detail emerging topics such as how to
register/de-register an MSB, using SARs to detect unregistered MSBs, the
increasing frequency of SARs indicating mortgage loan fraud, and filing SARs
after being served with a grand jury subpoena. Below is a detailed view of
topics discussed in this issue.
• Section 1: Director’s Forum;
• Section 2: Trends and Analysis – SARs related to unregistered/
unlicensed MSBs as reported by depository institutions and mortgage
loan fraud;
• Section 3: Law Enforcement Cases – an example of how the Federal
Bureau of Investigation (FBI) is utilizing BSA data to investigate
terrorist financing cases and summaries of BSA data used in criminal
investigations;
1 Participants include, among others, the American Bankers Association; Independent Community
Bankers of America; American Institute of Certified Public Accountants; Securities Industry
Association; Futures Industry 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. Department
of Justice’s Criminal Division and Asset Forfeiture & Money Laundering Section and the Federal
Bureau of Investigation; 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.
1