The SAR Activity Review Issue 12 - FinCEN

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.
We are 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.
We 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.
1