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FinCEN is issuing this Notice to provide administrative relief to sellers and providers of prepaid access that would otherwise be subject to certain Bank Secrecy Act ("BSA") requirements imposed by a final rule published on July 29, 2011 (the "Final Rule").1 As a result of this…
My money services business understands that Bank Secrecy Act regulations (31 C.F.R. Part 103) require, among other things, implementing a written anti-money laundering program and maintaining records of certain transactions. Because of the nature of my business, I would prefer to…
In March 2002, the founder and former president of a small bank pled guilty to structuring financial transactions. The banker had earlier argued that he was merely trying to gain customers for the bank. The case involved the banker asking an individual if he and his father could deposit money at…
An investigation into the exportation of stolen merchandise exposed that the defendant was using a check kiting scheme to defraud local area banks resulting in losses exceeding $50,000. Subsequent to the defendant’s bond hearing, the defendant fled the jurisdiction and continued to engage in…
The former head of an investment firm was sentenced to nearly five years in prison as a result of a guilty plea to one felony count each for mail fraud and filing a false tax return, in a $146 million dollar scheme that targeted senior citizens. The subject pled guilty for his role in the…
A jury found the defendant guilty of structuring after a pattern of transactions designed to evade currency transaction reporting requirements was identified. Prosecutors did not allege that the structured funds were derived from criminal activity.
The jury found the defendant guilty of…
A doctor who distributed more high powered pain pills than the largest regional medical center was brought to justice with the help of BSA records. In these types of investigations, proving that the prescriptions for pain relief are unwarranted can be very difficult because doctors often follow…
BSA records helped identify co-conspirators, accounts, and elements of a mortgage fraud scheme that may total as much as $7 million dollars in losses. SAR filings described transactions related to the fraud in both personal and business accounts belonging to the defendant in the case, and CTRs…