Money Laundering, Terrorism and Financial Institutions - USA Patriot Act Monitor

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10/16/2006 FinCEN Director Notes High Correlation of Terrorism-Related SARs to FBI Investigations

Speaking at a money laundering enforcement conference presented by the American Bankers and American Bar Associations on October 9, FinCEN Director Robert Werner noted that defensive filing was turning out to be less of a problem than had been expected. The Director said that even after high profile enforcement actions were taken, FinCEN was finding that the reports in the resultant spike in SAR filings still tended to be of high quality. The Director said that the FBI recently reviewed SARs coded as suspected terrorist financing and matched those SARs against active investigation case files. It found that 20% of terrorism-related SARs contained subjects of open FBI terrorism investigations. The Director called this “incredibly impressive given the difficulty of detecting terrorist financing activity.” FinCEN is studying whether institutions regularly filing SARs that correlate with FBI targets have common aspects in their AML programs. In sharing BSA data with law enforcement, the Director also touted the IRS-developed WebCBRS for providing user-friendly and intuitive access to the data.

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