The Cornerstone Report: Volume 2, Issue 2

Spotlighting ICE’s SAR Review Teams

ICE’s Washington, DC/Northern Virginia Field Office is actively targeting money launderers, illegal money service businesses (MSBs) and other financial fraudsters in the region. The Office of the Special Agent-in-Charge, Washington, DC’s SAR review team and others like it around the country are comprised of special agents, intelligence analysts and state and local task force officers with special training in conducting complex financial criminal investigations.

Marcy M. Forman, Director of ICE Office of Investigations, has made financial investigations a priority at every ICE SAC office in the United States. Staff judiciously examine financial documents, bank records and other financial reports in their pursuit to find the financial crimes investigator’s equivalent of the “smoking gun”—structured cash deposits, illegal wire transfers to foreign countries, or other indicators of illegal financial activity.

SARs are a vital component in the fight to combat serious financial crimes; many SAC offices created SAR review teams to sort through the multitude of reports that are filed from banks and other financial institutions nationwide. SARs provide potentially significant data that may identify potentially serious violators of the Bank Secrecy Act (BSA) and related crimes.

The SAR itself is not direct evidence of a crime—it is a report of suspicious activity that MAY be indicative of criminal activity. ICE agents utilize the information contained in the SAR to evaluate whether or not the activity reported rises to a level that warrants further investigation. The BSA, which created the SAR reporting requirement, places strict limitations on the manner in which SARs can be used. The disclosure of the existence of a SAR to unauthorized individuals (including the subject of the SAR) is strictly prohibited. Despite these limitations, the SAR is and will continue to be a valuable tool in combating money laundering, terrorist financing, and other serious financial crimes.

The following cases were identified and successfully investigated through the efforts of ICE SAR reviews:

• SAR information led to an ICE investigation of a California man who defrauded a bank of hundreds of thousands of dollars by obtaining stolen checks and depositing them into his own account under a fictitious name. This investigation showed that the man was attempting to further defraud the bank of well over $1 million before he was arrested. The defendant was ordered to make restitution to the bank as part of his sentence.

• Based upon SAR information, an Atlanta-area business was targeted for investigation by ICE agents for failing to register with the Financial Crimes Enforcement Network (FinCEN) as a money service business (MSB). Investigation showed that the owner of this business deposited in excess of $1 million into a bank account, which was subsequently wired abroad to several financial institutions. As a result, agents seized over $100,000 in currency and property from the violator.

• A bank employee was discovered to be involved in structuring and other Bank Secrecy Act violations based upon SAR information filed by a National Capitol Region financial institution. In addition, the funds used as part of the scheme were discovered to have been smuggled from Central America into the United States to avoid currency reporting requirements. The defendant pled guilty to structuring cash deposits and was ordered by the judge to forfeit the currency involved in the scheme.

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Suspicious Activity Reports: A Critical Tool for Financial Investigations

Spotlighting ICE’s SAR Review Teams

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Cornerstone Calendar

Cornerstone is U.S. Immigration and Customs Enforcement's (ICE) comprehensive investigative initiative for fighting financial crime, trade fraud and intellectual property crime.

The Cornerstone Report is a quarterly bulletin highlighting key issues related to ICE financial and trade investigations.

The Cornerstone Report covers a broad range of topics related to financial investigations and potential vulnerabilities in the financial and trade sectors.

We strive to present clear thinking by knowledgeable observers that can be read with ease and pleasure by both professionals and a general audience, and we’re happy to review unsolicited submissions for potential publication in the newsletter.

If you would like to submit an article for publication or simply find out more about how you can participate in the Cornerstone initiative, drop us an e-mail at tripwire@dhs.gov.