Compliance Blog

Written by Bernadette Clair, Regulatory Compliance Counsel

If you’ve ever wondered what happens to all those SARs credit unions file, day in and day out, you’re not alone.  Given the regulatory burden and cost associated with BSA compliance, it isn’t any wonder that every once in a while someone wonders…is anybody reading this stuff? Or are we just wasting our time filing reports that fall into some black hole never to be seen again?

For those of us who like to see tangible results, law enforcement case examples provided by FinCEN confirm SARs don’t fall into a black hole – they are used by law enforcement and can lead to investigations, indictments, and convictions.  These case examples can be found in FinCEN’s periodic SAR Activity Review – Trends, Tips, & Issues (access the most recent issue here).  Current and past case examples are also available on FinCEN’s website here. 

 Here’s a list of the most recent law enforcement case examples from the 21^st issue of the SAR Activity Review – Trends, Tips, & Issues:

• Proactive Suspicious Activity Report Review Leads to Indictments in “Cash Back” Mortgage Fraud Scheme
• Bank Secrecy Act Records Detail Transactions Related to Illicit Smoke Shop Sales
• Bank Secrecy Act Document Analysis Helpful in Fraud Case
• FinCEN Information Helps Jury Convict Cocaine Trafficker
• Proactive SAR Review Leads to Guilty Pleas in Structuring, Bank Fraud Case
• Suspicious Activity Reports Document International Payments Underlying Illicit Human Growth Hormone Trafficking
• Proactive SAR Review Identifies Retired U.S. Military Officer Involved in Bribery Scheme

These case examples also serve as a great resource for coming up with ideas for training credit union staff and directors on BSA compliance issues.