- Chief Compliance Officer and VP of Legal Affairs, Arrow Electronics
By 
Aaron Nicodemus2023-04-27T16:22:00
What does the Treasury Department’s Financial Crimes Enforcement Network (FinCEN) do with the millions of suspicious activity reports (SARs) it receives every year? If you work at a financial institution, you’ve likely wondered whether these SARs are ever even read, no less acted upon.
The Bank Secrecy Act (BSA) requires approximately 260,000 financial institutions to have policies and procedures in place to identify and report suspicious activity within their transactions. Suspicious activity consists of money laundering, terrorist financing, or financing of weapons of mass destruction (proliferation financing).
In its year in review for fiscal year 2022, published Tuesday, FinCEN laid out the law enforcement investigations derived from the 4.3 million SARs filed in FY2022. The period covered began Oct. 1, 2021, and ended Sept. 30.
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The Financial Crimes Enforcement Network issued a notice to financial institutions regarding its observations of increasing payroll tax evasion and workers’ compensation fraud taking place in the U.S. residential and commercial real estate construction industries.
Good suspicious activity reports make it easier for financial intelligence units to prioritize and process investigations, enabling better results in the global fight against financial crime.
Merrill Lynch was assessed penalties totaling $12 million by the Securities and Exchange Commission and Financial Industry Regulatory Authority for allegedly failing to file nearly 1,500 required suspicious activity reports over the course of a decade.
Three former executives of Chicago-based Outcome Health, a healthcare technology company, were sentenced for misleading an auditor, clients, lenders, and investors about a scheme to sell $45 million in overbilled advertisements.
A home health company operating in Indiana, Ohio, and Texas agreed to pay nearly $4.5 million to settle allegations it filed false claims by giving sports tickets and other kickbacks to assisted living facilities in exchange for referrals.
Crypto-friendly Silvergate Bank will pay a total of $63 million penalties to California and the Federal Reserve Board to settle charges that its anti-money laundering program failed to properly monitor more than $1 trillion worth of customer transactions.
