Under terms of the Bank Secrecy Act (BSA), there currently are hundreds of thousands of financial institutions subject to BSA reporting and recordkeeping requirements, for which the Financial Crimes Enforcement Network (FinCEN) is authorized responsibility. These include:
- Depository institutions, e.g., banks, credit unions and thrifts
- Brokers or dealers in securities and/or futures
- Money services businesses (MSBs) [e.g., money transmitters; issuers, redeemers and sellers of money orders and travelers' checks; check cashers and currency exchangers]
- Casinos and card clubs
- Insurance companies
- Mutual funds
Whenever one of these institutions encounters questionable financial activity - a deposit or withdrawal in excess of $10,000, for instance - it is supposed to file a Suspicious Activity Report, or SAR. These SARs routinely uncover suspected money-laundering activities, such as those which recently led to the resignation of New York ex-Gov. Eliot Spitzer.
According to FinCEN's publication, The SAR Activity Review, over 4.7 million SARs were filed with FinCEN between 1996 and June 30, 2007. An interesting trend to note: Since January 1, 2003, filings by non-depository institutions - casinos, insurance companies, etc. -- have grown to encompass a greater portion of the SARs filed. In 2001, 96 percent of the SAR database consisted of depository institution Suspicious Activity Reports; today figure is 64 percent.
Because the SAR is the backbone of an effective anti-money laundering (AML) defense, writing an effective one to meet regulatory requirements is an essential skill for a financial institution.
In this exclusive webinar, hear from Kevin Sullivan, a renowned AML expert and veteran New York State Police investigator who has 20 years of police experience and who reviews as many as 4000 SARs per month.
Understand what transpires once you send a SAR into FinCEN. Listen to Sullivan's practical, hands-on advice to help your institution determine:
- Who needs to file these reports?
- When should a SAR be filed?
- What are the reasons to file them?
- How to complete a proper and quality SAR;
- Suitable SAR narrative writing guidelines and appropriate SAR etiquette.
From his years as the state investigation coordinator at the NY High Intensity Financial Crime Area (HIFCA) El Dorado Task Force, which reads over 4000 SARs per month, you will hear the unique perspective of someone who has seen how all financial institutions prepare their SARs. Kevin will detail some of the methods that law enforcement use while gathering financial intelligence, such as:
- Desktop Bounty Hunting;
- Pro-Active Targeting;
- SAR Review Meetings
Additionally, Kevin will speak about several successful cases that have come from SARs and the SAR review process.