August 2016

In 2003, Bureau of Immigration and Customs Enforcement agents initiated an investigation of several non-profit organizations in the United States. These were all registered as tax-exempt organizations. The investigation revealed the organizations were operating as illegal wire remitting businesses, allegedly co-mingling drug proceeds with donations. Suspicious Activity Report documentation revealed approximately $3 million in transactions during a three-month period.

The United States Secret Service, New York Field Office, seized over $5.3 million from a correspondent account for a bank headquartered in Nigeria. Investigative leads derived from Bank Secrecy Act data determined that this account was actually owned by the Nigerian bank and operated by the bank’s president and chairman of the board of directors.

In what a federal prosecutor called “the most blatant currency structuring case” he had seen, a federal judge sentenced an 82-year-old man in March 2007 to 15 months in prison and ordered him to pay $110,000 in restitution to American victims of an international lottery scheme. The defendant had been involved in several suspicious investment schemes over the past few years, and numerous SARs document a string of unusual transactions. In addition, the investigating FBI agent reported that he would not have been able to make the case without the SARs.

SARs filed by a bank resulted in the initiation of an investigation by the IRS. Three (3) family members pled guilty to conspiring to obstruct the IRS from ascertaining their true income tax liabilities for tax years 1978 through 1995 by filing false tax returns and structuring currency transaction in amounts less than $10,000. The individuals skimmed cash receipts, which they kept in safety deposit boxes, from their three businesses. The father and mother concealed their taxable incomes by commingling their assets with each other and their son in multiple business and personal accounts.

Suspicious Activity Reports (SARs) played a critical role in the indictment and guilty plea of a weight-loss doctor. The doctor ostensibly ran a weight-loss clinic, but in reality orchestrated a scheme to provide prescriptions for cash. In fact, innocent patients noticed that the doctor’s office operated in an unusual manner. A SAR review team initiated the investigation.

A bank employee devised a scheme to embezzle funds from work through a complex scheme that lasted more than 2 ½ years. The scheme involved automated debit and credit transactions conducted through multiple accounts. The Suspicious Activity Report (SAR) filed on the theft details how the fraud took place and laid the groundwork for successful prosecution.

In a case where investigators believe that as much as $7 million in losses may be realized, Bank Secrecy Act (BSA) records helped identify co-conspirators, accounts, and elements of a mortgage fraud scheme. Specifically, Suspicious Activity Reports described transactions related to the fraud in both personal and business accounts belonging to the defendant. In addition, Currency Transaction Reports (CTRs) filed by a bank and a money services business (MSB), point to transactions enabling the defendant to obtain cash from the fraudulent activity.

In a case initiated from a Suspicious Activity Report (SAR), investigators found perpetrators were operating two separate fraud schemes. The first scheme, a check-kiting fraud, was only possible because of the complicity provided by the chief defendant’s wife who worked at the bank where the fraud occurred. In the second scheme, the defendant and a group of co-conspirators defrauded auto insurance companies of more than a million dollars. The SAR on the first scheme led investigators to the discovery of the auto insurance fraud.

Investigators looking at a drug trafficking organization were helped by Suspicious Activity Reports (SARs) that a bank filed on an individual who laundered the illicit proceeds. Prosecutors charged that individual with hiding more than $800,000 belonging to an accused drug dealer involved in a murder-suicide. For several years, the bank meticulously filed SARs on the defendant, a long-time customer who suddenly changed his banking habits.

Federal law enforcement and regulatory agencies conducted a securities fraud investigation where defrauded investors lost at least $32 million. Investors believed they were investing in coal mines and a huge and highly secretive gold transaction. Three individuals were convicted of running the scheme and sentenced to lengthy prison terms.