Suspicious Activity Reports and You
Did you ever wonder what happens to all of those Suspicious Activity Reports (SARs) that you are required to file? Do they disappear into some bureaucratic black hole, never to be put to any useful purpose? Well, you’ll be pleased to learn that your efforts in completing timely and thorough SARs have been providing extremely valuable tools to state and federal law enforcement agencies right here in Connecticut.
Since 2002, a group coordinated by the United States Attorney’s Office meets each month to review every SAR filed by Connecticut banks and other financial institutions during the previous month. This SAR Working Group consists of federal and state investigative agencies including the Federal Bureau of Investigation, the Drug Enforcement Administration, the Internal Revenue Service, the Bureau of Immigrations and Customs Enforcement, the Social Security Administration Office of the Inspector General, the Secret Service, the Federal Deposit Insurance Corp., the U.S. Postal Inspector, the Connecticut Department of Banking and the Chief State’s Attorney’s Office.
This working group uses the SARs to identify individuals who may be engaged in structuring and/or other criminal activities. Indeed, while the SARs typically report suspected structuring activities, the group’s experience thus far indicates that, in many instances, financial transactions are being structured in an effort to conceal other types of more serious crimes. In fact, the SARs aid in the investigation of a whole host of criminal activity, including operating an unlicensed money-transmitting business, bank fraud, tax fraud, money laundering and terrorist financing.
Moreover, the working group has had some early success to report. Just as an example, as a result of the SAR review initiative, the United States Attorney’s Office prosecuted a New Haven woman for structuring approximately $1.3 million in cash into two local bank accounts and then unlawfully wire-transferring the money out of state. Since this woman was not registered as a money-service business with the state of Connecticut or FinCEN, she was also prosecuted for operating an unlicensed money-transmitting business. She was sentenced to 18 months of incarceration. Unfortunately, the defendant’s bank accounts were depleted by the time the government learned of her criminal activities. In the future, the working group anticipates that it will more aggressively target and seize the bank accounts involved in the criminal activity before the accounts can be depleted.
The early success of this program is due in part to the conscientious efforts of the many bank tellers and managers who report suspicious transactions and who have forged cooperative working relationships with many of the federal agents with whom they come in contact. The U.S. Attorney’s Office appreciates the diligent compliance with the SAR reporting obligations and looks forward to working with you in the future.
If anyone has questions regarding the SAR review initiative or is interested in having a representative from the U.S. Attorney’s Office speak at any of your upcoming conferences, please feel free to contact Assistant United States Attorneys Mark Rubino or Peter Jongbloed at (203) 821-3700.