The SAR Activity Review Issue 12 - FinCEN

BSA/Structuring/Money Laundering violations involved activities in which the
subjects structured deposits and withdrawals of convenience, credit card, and
courtesy checks. As soon as the funds were available, the suspect withdrew the
funds, wrote checks, and made purchases. The financial institution sustained
financial loss when the checks were later returned for insufficient funds.
Suspicious Activity Reports filed by Depository Institutions
A search of the financial database for the period of April 1, 1996 through March
31, 2007 revealed 14,670 depository institution SARs filed with the specific
search terms included in the narrative. Of those SARs, 11,245 listed convenience
check(s); 3,163 listed credit card check(s); and 262 listed courtesy check(s). Exhibit
2 illustrates the activity by year.
2500
2000
1500
1000
500
0
Exhibit 2: Depository Institution Suspicious Activity Reports Filed for the
Period of January 1, 2002 through March 31, 2007
1,285
351
14
1,446
520
20
1,424
392
Monetary Value Involved: The total dollar amount reported by depository
institutions in the suspicious activity for the review period was $1,153,551,294.
One single filer reported an activity amount of $150 million. 3 Over 33% of the
reports fell into the range between $5,000 and $9,999. Exhibit 3 illustrates the
activity by dollar amounts.
15
1,838
572
49
2,353
2002 2003 2004 2005 2006 2007
Convenience Check(s) Credit Card Check(s) Courtesy Check(s)
3 The SAR narrative described two credit card checks, each written in the amount of $75 million and
dropped in a financial institution’s after-hours depository.
630
72
650
169
18