01-RA-11, Suspicious Activity Report (SAR)

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REGULATORY ALERTNATIONAL CREDIT UNION ADMINISTRATION1775 DUKE STREET, ALEXANDRIA, VA 22314DATE:October 2001TO:All Federally-Insured Credit UnionsSUBJECT:Suspicious Activity Report (SAR)ENCL:(1)(2)(3)NO.:01-RA-11SAR Bulletin, Issue 3, June 2001Identity Theft Highlighted in SAR Activity Review, June18, 2001SAR Activity Review – Trends, Tips & Issues, Issue 2,June 2001The purpose of this regulatory alert is to forward a copy of the June 2001 issue ofSAR Bulletin, published by the Department of the Treasury’s Financial CrimesEnforcement Network (FinCEN). The publication is part of a series of overviewsof trends and patterns in money laundering derived from the Suspicious ActivityReport (SAR) database that can help financial institutions prevent and detectfinancial crime. The SAR Bulletin also may be found on FinCEN’s Web site atwww.treas.gov/fincen.Also attached is a copy of the second edition of The SAR Activity Review,published semiannually by FinCEN. The publication provides feedback to financialinstitutions about suspicious activity reported to FinCEN by the institutions. Itcontains SAR statistics; patterns and trends of suspicious activity that have beenreported; tips and guidance for financial institutions on form preparation and filing;and information about law enforcement cases in which SAR information played animportant role in a successful investigation and/or prosecution of criminal financialactivity. The SAR Activity Review and FinCEN's press release about thepublication also may be found on FinCEN's Web site.Sincerely,/s/Dennis DollarChairman

SAR BulletinInformation drawn from the Suspicious Activity Reporting SystemIssue 3June 2001Suspicious ActivityRelated to PhoneCard BusinessesA review of Suspicious ActivityReports (SARs) filed with the TreasuryDepartment s Financial Crimes Enforcement Network (FinCEN) identified over 160 reports indicating suspicious financial activity related to businesses involved in phone card sales.Some of the companies or businessesinvolved in the reported activity offerother services such as check cashing,money orders, beepers, cellular phones,faxes, lottery tickets, and travel tickets.This activity has been observed byfinancial institutions in fourteen states,particularly in New York, New Jersey,Texas, California, and Florida.Businesses involved in phone cardsales routinely generate significantlegitimate cash flow. However, SARinformation reported by financial institutions characterizes the types of problematic transactions suggestive ofmoney laundering or other illicit financialactivity (large and unexplained cashflow increases, transactions structuredto stay below CTR reporting requirements, etc.) associated with illegitimateuse of these businesses. Additionally,law enforcement information indicatesthat phone cards are being used as amechanism to launder funds.The suspicious activity reported byfinancial institutions that may reflectillicit use of phone card businesses fallsinto the following categories:punusual deposit of funds into orwithdrawal of funds from bankaccounts maintained bybusinesses engaged in phonecard activity;pcash deposits containing a largenumber of 100 bills;punexpectedly large transactionsoccurring over relatively briefperiods of time;plack of, or improbable reasonsfor financial activity;pfrequent structured transactionsfollowed by immediatewithdrawals;punusual outgoing wire transfers,cashiers check purchases, checkcashing, and check and moneyorder deposits;punexpected check cashing activityoccurring at businesses whoseprincipal activity is phone cardsales;psmall retailers suddenly orirregularly experiencing highvolumes of phone card sales, withaccompanying major increases incash deposits.The reported dollar volumes associated with these activities range fromUnited States Department of the Treasury . Financial Crimes Enforcement Network

300,000 to 50 million. In one instance,information from the SARs indicated thatover 50 million in deposits (checks,cash, and money orders) were received inone year by a communications companyinvolved in the sale of prepaid telephonecards by convenience stores. In anotherinstance, a bank reported 370 cashdeposits by a prepaid phone card business totaling more than 3 million inapproximately three months, exceedingthe business s expected cash flow. In athird case, a bank reported a homebased phone card business with morethan 500,000 deposited within a twomonth period. Another scenario involveddaily cash deposits of 9,000 from aphone card business continuing over aneight-month period. In some instances,the use of phone cards and the connection with volume wholesale or retail salesof phone cards were central to thesuspicious activity. In other cases, thephone card connection appeared as anadjunct to the main suspect activity.What to do:Financial institutions should alert keypersonnel to the possible use of phonecard sales to facilitate and/or concealmoney laundering. Financial institutionsshould be sensitive to financial transactions by phone card businesses, retail orwholesale, when those businesses generate cash flows that are well beyond theirnormal business activity. The specificsuspicious activity/methodology observedthat involves phone cards and/or businesses involved in phone card salesshould be described fully in the narrativesection of the SAR, including the involvement of participants in foreign countries.For additional information, comments,or questions concerning suspiciousphone-card-related transactions, pleasecall FinCEN s Office of Strategic Analysisat (703) 905-3545.James F. Sloan, DirectorThis SAR Information Bulletin is part of a series of overviews of trends andpatterns in money laundering derived from the SAR database. The SARInformation Bulletin Series is designed to highlight activities or issues thatappear significant based on such factors as number of reports, number offinancial institutions filing similar reports, aggregate dollar values,geographic distribution, and especially recurrent patterns of activity identifiedin SAR narratives. In no cases will information relating to particularinstitutions, businesses, or individuals be included in any Bulletin. Whetherthe information in a particular Bulletin is of relevance to a particular financialinstitution, of course, depends in many cases upon that institution soperating realities. In all cases, comments or other feedback would bewelcome. Please forward comments on SAR Bulletins to the Financial CrimesEnforcement Network at 703-905-3698 (fax) or email ora@fincen.treas.gov.SAR Bulletin is a product of the Financial Crimes Enforcement Network,U.S. Department of the Treasury, 2070 Chain Bridge Road, Vienna VA 22182.Please forward comments on SAR Bulletins to FinCEN at 703-905-3698 (fax) or emailora@fincen.treas.gov. For more information about FinCEN's programs, visit the FinCEN web siteat http://www.treas.gov/fincen. General questions or comments regarding FinCEN publicationsshould be addressed to the Office of Communications, FinCEN, (703) 905-3773.Information may also be faxed to (703) 905-3885.

U.S. Department of the TreasuryFinancial Crimes Enforcement Networknews2070 Chain Bridge Road, Suite 200, Vienna VA 22182-25361099 14TH Street NW, Suite 400, Washington D.C. 20005FinCEN's web site is located at: http://www.treas.gov/fincenFOR IMMEDIATE RELEASEJune 18, 2001Jane Fisher or Sheri James, FinCEN(703) 905-3770Identity Theft Highlighted in SAR Activity ReviewThere has been a dramatic increase in the number of incidents of identity theft reported bybanks on suspicious activity reports (SARs). This finding is reported in the second issue of the SARActivity Review – Trends, Tips and Issues, a collaborative report being released today whichprovides feedback to the financial, law enforcement and regulatory communities based on analysisof the SAR data.In 1997, the first full year of required SAR reporting, 44 instances of identity theft werereported. From January to November 30, 2000, there were 617 SARs filed reporting identity theft.The Review provides further insight into patterns of criminal financial activity associated withidentity theft through the analysis of SAR data.For instance, SARs indicate the fraudulent use of social security numbers to obtain car loansfor high-end vehicles. In most cases, the bank is alerted to the scheme because the perpetratorimmediately defaults on the loan payments; however, it is a difficult task for the bank to determinewho actually purchased or leased the vehicle in question. In another common scenario, a victim'smail is stolen, which often includes bank or convenience checks issued by credit card companies.The victims are often unaware that the thief is writing checks against their account until theyreceive a monthly statement from the bank or credit card company.The Review, the first of which was issued in October 2000, represents a vital, cooperativeeffort involving financial services representatives, federal law enforcement and regulatory agencies.Included in the report are SAR statistics, patterns and trends of suspicious activity that have beenreported, law enforcement investigations that incorporated SAR information, tips and guidance forfinancial institutions on form preparation and filing, and an industry forum.FinCEN Director James F. Sloan commended the collaborative efforts of all involved toproduce this latest report. “The Review is one of the best examples of the type of cooperation thatdefines the FinCEN network, ” he said. “This on-going effort is absolutely essential to ourcontinuing commitment to provide law enforcement, regulators and the regulated industry withmeaningful information about the utility of Suspicious Activity Reports.”

- more John Byrne, senior counsel and compliance manager for the American Banker’s Associationand co-chair of the SAR Activity Review project with FinCEN, concurred with the importance ofinformation sharing among law enforcement, regulators and industry. “This information onidentity theft filings will greatly assist the public-private efforts in reducing this crime. The SARReview remains a tremendous resource for our members,” said Byrne.Financial institutions were required to begin filing SARs in April of 1996 to assist lawenforcement in detecting and prosecuting violations of money laundering and other financialcrimes. The SAR system replaced the “criminal referral reporting” system that had been in placesince 1984. As the SAR program matured, feedback among law enforcement, regulators and theregulated industry about the value of the information being reported was recognized as animportant part of on-going efforts to further refine the quality of SAR information.Among those that participated in this review were: the American Bankers Association;Independent Bankers Association; Independent Community Bankers of America; AmericanInstitute of Certified Public Accountants; Securities Industry Association; Non-Bank FundsTransmitters Group; Federal Reserve Board; Office of the Comptroller of the Currency; FederalDeposit Insurance Corporation; Office of Thrift Supervision; National Credit UnionAdministration; Federal Bureau of Investigation; U.S. Department of Justice’s Asset Forfeitureand Money Laundering Section; U.S. Department of Justice’s Criminal Division; U.S.Department of the Treasury’s Office of Enforcement; U.S. Customs Service; U.S. Secret Service;Internal Revenue Service; and Financial Crimes Enforcement Network.The Review will be available on FinCEN’s website today. Copies may also be obtainedby calling FinCEN’s publications line at 703/905-3773.###

TheSARActivityReviewTrendsTips &IssuesIssue 2Published under the auspices of the Bank Secrecy Act Advisory GroupJune 2001

Table of ContentsIntroduction . 1Feedback Form . 2Section 1 SAR Statistics . 4Section 2 National Trends and Analyses . 141. Highlighted Trend . 142. Other Notable Trends . 183. Other SAR Analysis Issues . 19Section 3 Issues with International Impact . 22Section 4 Law Enforcement Cases . 26Section 5 Tips on SAR Form Preparation & Filing . 32Section 6 Issues and Guidance . 35Section 7 Industry Forum . 38Section 8 Index of Information SourcesReleased since October 2000. 40This is a PDF version of a printed document. Although page numbers have been adjusted to provide easy navigation and electronicviewing, no information has been omitted from this publication.

IntroductionThe SAR Activity Review Trends, Tips and Issues is the product of a continuingdialog and close collaboration among the nation s financial institutions, federallaw enforcement officials, and regulatory agencies to provide meaningful information about the preparation, use, and value of Suspicious Activity Reports(SARs) filed by financial institutions.This publication reflects the recognition of both the relevant government agenciesand the nation s financial institutions of the desirability of a continuing exchangeof information between the private and public sectors to improve the SAR System. These include, among others, the American Bankers Association; Independent Bankers Association; Independent Community Bankers of America; American Institute of Certified Public Accountants; Securities Industry Association;Non-Bank Funds Transmitters Group; Federal Reserve Board; Office of theComptroller of the Currency; Federal Deposit Insurance Corporation; Office ofThrift Supervision; National Credit Union Administration; Federal Bureau ofInvestigation; U.S. Department of Justice s Criminal Division, and Asset Forfeiture and Money Laundering Section; U.S. Department of Treasury s Office ofEnforcement; U.S. Customs Service; U.S. Secret Service; Internal RevenueService; and Financial Crimes Enforcement Network.The SAR Activity Review is published semi-annually. The first issue was released inOctober 2000. Analytic reports, issue papers, and other publications related to orresulting from information contained in the Review may be published separately.Questions, comments and other feedback concerning the SAR Activity Review aremost welcome. Where possible, Email contact points are provided in the sectionsof the SAR Activity Review. A feedback form is provided on the next page. Comments may also be addressed to either or both of the SAR Activity Review projectco-chairs:John J. ByrneSenior Counsel andCompliance ManagerAmerican Bankers Association1120 Connecticut Ave., NWWashington, DC 20036(202) 663-5029 (phone)(202) 828-5052 (fax)jbyrne@aba.com1David M. VogtAssistant DirectorOffice of Strategic AnalysisFinancial Crimes Enforcement Network2070 Chain Bridge Road, Suite 200Vienna, VA 22182(703) 905-3525 (phone)(703) 905-3698 (fax)vogtd@fincen.treas.gov

Feedback FormDepartment of the Treasury . Financial Crimes Enforcement NetworkA. Please indicate your level of satisfaction with the eight sections of the SARActivity Review.(Circle One for Each Row)1 Not Useful, 5 Very Usefula.b.c.d.e.f.g.h.SAR StatisticsNational Trends and AnalysesIssues with International ImpactLaw Enforcement CasesTips on SAR Form Preparation and FilingIssues and GuidanceIndustry ForumIndex of Information Sources1111111122222222B. How do you use this Report?a.b.c.d.e.f.g.h.TrainingBackground Information ResourceAnalytic ToolIncrease Management AwarenessComparison of statisticsMake changes to your compliance programAudit/Exam preparationOther (identify)C. Did you read the first issue (October 2000)?a. Yesb. NoD. If the answer to C is Yes, did you circulate it to:a.b.c.d.2Your staffYour colleaguesSenior managementBoard/audit committee333333334444444455555555

E. Have you discussed the SAR Activity Review at management meetings?F. If the answer to C is Yes, how did you receive the Review?a.b.c.d.At the ABA/ABA Money Laundering Enforcement SeminarOn an Agency s WebsiteFrom a Law or Accounting FirmOtherG. Which of the following best describes your job position? (Check One)a.b.c.d.e.f.g.h.i.[ ] CEO/COO[ ] Compliance[ ] Risk Management[ ] Operations[ ] Legal[ ] Audit[ ] Security[ ] Government[ ] OtherH. Any additional suggestions or comments?Thank you for your feedback.Send your Feedback Form to:FinCEN Office of Strategic AnalysisFax 703-905-3698Ora@fincen.treas.govorAmerican Bankers AssociationFax 202-828-5052Jbyrne@aba.com3

Section 1Suspicious Activity Report Statistics1April 1, 1996 - December 31, 2000The statistics on the following pages relate to SARs filed since April 1996 bydepository institutions (i.e., banks, thrifts, savings and loans, and credit unions).A small part of the total volume relates to reports filed by affiliates of depositoryinstitutions or, in some cases, filed voluntarily by brokers and dealers in securitiesthat are not affiliated with banks, money services businesses, or gaming businesses that have no regulatory requirements at this time that mandate SAR filings.Note: SAR statistical data is continuously updated as additional reports are filed andprocessed. For this reason, there may be minor discrepancies between the statisticalfigures contained in various portions of this report.Exhibit 1SAR Filings by Year and MonthNumber of 2120,506156,931Statistics generated for this study were based on the Document Control Number (DCN) of each recordwithin the SAR system. The DCN is a unique number assigned to each SAR submitted. Numeric discrepancies between total number of filings and the combined number of filings of states and/or territories is a resultof multiple filers listed on one or more SARs.

Exhibit 2SAR Filings by States and Territories For the Period April 1, 1996 through December 31, 2000 State/TerritoryAlabamaAlaskaAmerican District of ColumbiaFederated States of 194213224000106159371,2011,5372,005Marshall 6371596Nevada6621,4882,0092,0623,011New Hampshire244503419573425New Jersey8881,5362,4373,4504,015Michigan51996

Exhibit 2 (cont.)State/TerritoryNew MexicoNew 117,93118,463North Carolina8931,6252,1192,3922,914North Dakota42215213122218Northern Mariana eas123972221,4522,4822,5443,5713,363Puerto Rico1465624563161,047Rhode Island155290285503483South Carolina279563640669711South 054,9066,2317,6069,453PennsylvaniaTexasU.S. Virgin t l61996

Exhibit 3Frequency Distribution of SAR Filings Ranked by Statesand Territories in Descending Order For the Period April 1, 1996 through December 31, 2000 erall)1California120,58023.75%2New a13,4122.65%8New 1%13Ohio10,3422%14North 5,4351.1%25Indiana4,764Less than 1%26Tennessee4,740Less than 1%27Louisiana4,603Less than 1%28Wisconsin3,297Less than 1%29South Carolina2,862Less than 1%30Oklahoma2,831Less than 1%31Hawaii2,751Less than 1%

Exhibit erall)(Overall)32Kentucky2,634Less than 1%33Puerto Rico2,527Less than 1%34Alabama2,404Less than 1%35South Dakota2,250Less than 1%36New Hampshire2,164Less than 1%37Kansas1,950Less than 1%38Iowa1,817Less than 1%39Arkansas1,785Less than 1%40Rhode Island1,716Less than 1%41Nebraska1,709Less than 1%42New Mexico1,426Less than 1%43District of Columbia1,422Less than 1%44Mississippi1,415Less than 1%45Idaho956Less than 1%46Maine932Less than 1%47Unknown/Blank826Less than 1%48North Dakota810Less than 1%49Alaska758Less than 1%50West Virginia742Less than 1%51Montana630Less than 1%52Vermont336Less than 1%53Guam316Less than 1%54Wyoming225Less than 1%55Northern Mariana Islands130Less than 1%56Overseas82Less than 1%57U.S. Virgin Islands65Less than 1%58American Samoa21Less than 1%59Federated States of Micronesia11Less than 1%60Marshall Islands1Less than 1%All percentages are approximate.

Exhibit 4Frequency Distribution of SAR Filings by Characterizationof Suspicious Activity in Descending Order For the Period April 1, 1996 through December 31, 2000 ucturing/Money Laundering255,65346%2Check Fraud71,62213%3Other39,9777.2%4Counterfeit 6Credit Card Fraud24,0544.3%7Check Kiting21,3063.85%8Unknown/Blank20,9633.8%9Mortgage Loan Fraud11,7032.1%False Statement11,4162.05%103State/Territory11Consumer Loan Fraud11,3622.05%12Mysterious Disappearance8,8721.6%13Misuse of Position or Self Dealing8,3451.5%14Commercial Loan Fraud4,819Less than 1%15Debit Card Fraud3,352Less than 1%16Wire Transfer Fraud3,121Less than 1%17Counterfeit Credit/Debit Card1,969Less than 1%1,564Less than 1%544Less than 1%65Less than 1%18Counterfeit Instrument (Other)19Bribery/Gratuity20Computer Intrusion4All percentages are approximate.Separate box on form for this violation was added in June 2000 TD F 90-22.47, and statisticsdate from that period.

Exhibit 5Frequency Distribution of SAR Filingsby Characterization of Suspicious Activity For the Period April 1, 1996 through December 31, 2000 Violation19961997199819992000BSA/Structuring/Money 150Check Fraud8,63913,27413,83216,23919,638Check 0000655Consumer Loan Fraud1,1482,0482,1852,5493,432Counterfeit CheckBribery/GratuityCommercial Loan FraudComputer Intrusion2,3174,2445,9187,3969,033Counterfeit Credit/Debit Card385387182351664Counterfeit Instrument 2605,1796,117False 632,186Mortgage Loan Fraud1,2651,7192,2682,9363,515Mysterious Disappearance1,1681,7671,8551,8572,225Credit Card FraudDebit Card FraudMisuse of Position or Self DealingWire Transfer ,149Unknown/Blank1,6522,3172,7287,2956,971Separate box on the form for this violation was added in June 2000 TD F 90-22.47, and statisticsdate from that period.

Exhibit 6SAR Filings by Primary Federal Regulator6 For the Period April 1, 1996 through December 31, 2000 RegulatorTotal Filings by Year1996Federal Reserve Board (FRB)5,486Federal Deposit Insurance Corporation (FDIC)9,839Office of the Comptroller of the Currency (OCC) 25,072Office of Thrift Supervision (OTS)5,760National Credit Union Administration 9,25590,14115,6103,42110,943Note: In the October 2000 issue of the SAR Activity Review, this chart erroneously reversed the data for NCUA and OTS. The above chart corrects this error.611Unspecified regulator indicates that the form was filed by a non-bank financial institution that isnot directly supervised by one of the five agencies listed above. Such entities which have noregulatory requirements for the relevant periods that mandate SAR filings include, but are notlimited to: Money Services Businesses; Insurance Companies; and Securities Brokers/Dealerswho are not affiliated with banks.

Exhibit 7Direct Referrals of SARs by Financial InstitutionsTo Law Enforcement7 and Regulatory Agencies For the Period April 1, 1996 through December 31, 2000 Exhibit 7 shows the number of times financial institutions that file SARs have alsodirectly referred certain situations to law enforcement officials. The direct referrals in this edition of the SAR Activity Review have been tabulated by countingeach agency to which a direct referral has been made. This method is appropriatesince a situation giving rise to a single SAR can be referred to more than oneagency. Such a tabulation accurately reflects the number of times particular lawenforcement agencies received SAR information directly from filing institutions.AgenciesFederal Law EnforcementFederal Bureau of InvestigationInternal Revenue ServiceU.S. Secret ServicePostal Inspection ServiceU.S. Attorney s OfficeU.S. Customs ServiceDepartment of TreasuryDrug Enforcement AdministrationNaval Criminal Investigative Service/U.S. NavyDepartment of JusticeSocial Security Administration (IG)Immigration & Naturalization ServiceSub-TotalOther Federal Law EnforcementTotal Federal Law EnforcementRegulatoryFederal Deposit Insurance CorporationFederal Reserve BoardOffice of the Comptroller ofthe 0130234,779 3,386 18,5272,118 1,083 9,2091,060746 5,532644728 2,9581061016088366364432320781271871494184935,057 9,04128635,085 9,1042000Total6171368108104111894112611328,493 8,880 6,303 37,7748380723268,576 8,960 6,375 es reflect those entities receiving five (5) or more SAR referrals. Some SARs may referencemaking referrals to multiple law enforcement agencies.

Exhibit 7 (cont.)AgenciesRegulatory (continued)Securities & Exchange CommissionOffice of Thrift SupervisionNational Credit Union AdministrationFederal Trade CommissionNational Association of SecuritiesDealersTotal RegulatoryState & Local Law EnforcementCity/Local Police DepartmentCounty/ParishD/A, A/G, or Prosecutor s Office8State PoliceOther State and LocalTotal State & Local LawEnforcementOtherPendingUnspecifiedPrivate Industry9Foreign Law Enforcement10FinCEN/DCCGRAND 54452951065,783 9,0597,588 7,994938 1,2533474012632891071358,586 35,5531,533 5,748373 1,883329 1,3571295669,243 10,072 10,950 45,107856405031185254184164234351 ,368 18,824 18,375 19,630 18,111 86,308City, County, or State.Includes referrals stating law firm, corporate security, etc.10Includes referrals made to Interpol.91998

Section 2National Trends and AnalysesThis section of the SAR Activity Review outlines examples and patterns of suspicious activity reported in the national database. Some of the information hasbeen published previously, but is included here for ease of reference.1. Highlighted TrendThe Highlighted Trend for this issue of the SAR Activity Review IdentityTheft was suggested by the financial industry as a topic of concern based onindustry perceptions of increases in both the incidence of identity theft-basedfraud and SAR reporting about the phenomenon. Results of FinCEN s analysis ofSAR data confirm these perceptions and provide insights into the patterns ofcriminal financial activity associated with identity theft on a national basis.Identity TheftIn October 1998, the Congress passed the Identity Theft and Assumption Deterrence Act of 1998 to address the problem of identity theft. Specifically, the Actamended 18 USC § 1028 to make it a federal crime for anyone to:knowingly [transfer] or [use], without lawful authority, a meansof identification of another person with the intent to commit, orto aid or abet, any unlawful activity that constitutes a violation ofFederal law, or that constitutes a felony under any applicableState or local law.While identity theft is not a new problem, advanced technology (in particular the Internet) is proving to be a powerful facilitator. According to the FederalTrade Commission (FTC) and law enforcement agencies, identity theft is increasing at an alarming rate. For example, in March 2000, the FTC received andresponded to roughly 400 such complaints and inquiries. The FTC currently logsapproximately 1,700 complaints and inquiries a week connected with all types ofidentity theft. Identity theft was the top consumer complaint received by the FTCduring calendar year 2000. 111114Washington Post. February 4, 2

Nov 30, 2000 · SUBJECT: Suspicious Activity Report (SAR) ENCL: (1) SAR Bulletin, Issue 3, June 2001 (2) Identity Theft Highlighted in SAR Activity Review, June 18, 2001 (3) SAR Activity Review – Trends, Tips & Issues,

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