The SAR Activity Review Issue 12 - FinCEN

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Sixty-one different financial institutions filed the 78 depository institution SARs
discussed in this section. The 78 depository institution SAR narratives contained
a total of eight different references to credit union cooperatives and affiliated
entities covered in this study.
Table 4 provides a statistical breakdown of the number of different sharedbranching
locations involved in the 78 depository institution SAR filings. Twentyseven
reports, or 34.61 percent of the total filings, involved transactions that
occurred at multiple shared-branching locations. Twenty-two of these reports, or
28.21 percent of the total filings, named members of cooperative-participant credit
unions as subjects. Fourteen filings involving multiple shared-branching locations
contained narrative references to money laundering or structuring. Thirteen
filings involving multiple shared branching locations had narrative references to
frauds or attempted frauds.
Table 4: DI SAR Narrative Referring to Covered Credit Union Cooperatives
– Breakdown of Shared-Branching-Transaction Locations
Shared-Branching-Transaction
Locations
Conclusion
DI SAR
Filings
% of
Total
With Credit
Union-Member
Subject
% of
Total
0 4 5.13% 0 0.00%
1 47 60.26% 40 51.28%
2 9 11.54% 6 7.69
3 14 17.95% 12 15.38%
5 2 2.56% 2 2.56%
6 2 2.56% 2 2.56%
Total: 78 100.00% 62 79.49%
FinCEN’s research on SAR filings for credit union cooperatives provides an indication
of the selected characterizations of suspicious activities currently being identified
within the credit union industry. FinCEN’s research also indicates that credit union
cooperatives’ SAR filings demonstrate a potential lack of consistency in the use of
filer names and FEINs, in addition to other errors. The number of filer-name and
FEIN variations in BSA filings related to these cooperatives could complicate future
efforts to correctly identify and aggregate SAR filings involving the cooperatives and
their affiliated entities. Data consistency problems and other data-quality issues
prolonged and hindered efforts to collect and evaluate data for this analysis.
In many cases, filers already have the information to correct errors, hence they can
improve the value of SARs to the law enforcement community at little or no cost to
the institution. FinCEN recently issued guidance on “Suggestions for Addressing
Common Errors Noted in Suspicious Activity Reporting.”
http://www.fincen.gov/SAR_Common_Errors_Web_Posting.pdf