August 2016

In early 2012, FinCEN conducted outreach to all of its state and local law enforcement partners, and asked for cases where FinCEN data played a useful role in their investigations. Below, in their own words, is an example of how FinCEN's stakeholders use FinCEN data. It has been edited only for confidentiality and privacy concerns. The following example is from an attorney general's office.

In early 2012, FinCEN conducted outreach to all of its state and local law enforcement partners, and asked for cases where FinCEN data played a useful role in their investigations. Below, in their own words, is an example of how FinCEN's stakeholders use FinCEN data. It has been edited only for confidentiality and privacy concerns. The following example is from an attorney general's office.

In early 2012, FinCEN conducted outreach to all of its state and local law enforcement partners, and asked for cases where FinCEN data played a useful role in their investigations. Below, in their own words, is an example of how FinCEN's stakeholders use FinCEN data. It has been edited only for confidentiality and privacy concerns.The following example is from a state agency case. FinCEN maintains Memoranda of Understanding with some state agencies that have criminal investigative authority in matters such as taxes, revenues, and gambling.

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 married couple structured millions of dollars through their retail cigarette business using multiple financial institutions and branches. The defendants’ businesses were dependent upon individuals purchasing the cigarettes for illicit tax-free sales in other states. To avoid scrutiny, the defendants structured the revenues from the cigarette sales. However, Suspicious Activity Reports (SARs) filed by multiple financial institutions not only helped investigators detect the scheme but provided critical details and leads.

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.