In 2008, financial institutions (FIs) submitted nearly 1.3 million Suspicious Activity Reports (SARs) to the Financial Crimes Enforcement Network (FinCEN).
But sometimes, a single complete and timely SAR can spur an investigation that helps put a fraudster behind bars. In 2009, for example, FinCEN, a division of the U.S. Department of the Treasury, reported the conviction of a mortgage broker who had structured more than $600,000 into multiple accounts at several banks.
Ultimately, the defendant admitted making numerous deposits of less than $10,000 each to avoid triggering bank filing of the Currency Transaction Reports (CTRs) required for all activity involving five figures or more.
In a single month, he made nearly 30 such deposits at a number of banks, totaling more than $260,000. Later, in almost 20 transactions at various branches of a single bank, he deposited an additional $185,000. That bank promptly filed a SAR detailing how the mortgage broker had deposited into his personal and business accounts sums ranging from $9,000 to $9,800.
A team of federal investigators then searched FinCEN’s database of millions of SARs and found related reports from other depository institutions and money services businesses indicating both cash structuring and structured purchases of money orders by and for the defendant.
Law enforcement officials credited the bank’s first SAR with providing the lead that prompted a more comprehensive investigation than otherwise would have been possible. Other SARs revealed the defendant’s purchase of large cashier’s checks payable to individuals with whom he had no known business relationship.
Case conclusion: The culprit awaits sentencing. Thanks to effective SARs and close teamwork by FIs, FinCEN, and federal agents, all leads were linked and investigated, and the defendant’s financial crime spree is over.