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Looking forward to @RepMaxineWaters, @AOC, and @katieporteroc taking turns shredding Deutsche Bank executives who decided the private banking division gets veto power over whether Suspicious Activity Reports are filed. A bank would only ever do that to conceal money-laundering.
/2 The standard for when a SAR must be filed is intentionally very low: if there's "reason to suspect" unlawful activity. Banks can't be sued by people for filing them. Banks can't even tell people a SAR was filed about them. Thus... ffiec.gov/bsa_aml_infoba… 
/3 ... banks have every incentive, and no disincentive, to file SARs. That's on purpose.
The only reason a bank would give SAR veto power to the same division involved if is the bank and the division felt the activity was likely illegal and would lead to a full investigation.
The only reason a bank would give SAR veto power to the same division involved if is the bank and the division felt the activity was likely illegal and would lead to a full investigation.
/4 Here's an example of how SARs are supposed to work, courtesy of Eliot Spitzer splitting up a wire transfer worth roughly $10,000. It's debatable if the bank was required to report it, but they correctly erred on the side of prudence and reported it given his political status.
And here's Trump accidentally confirming that Deutsche Bank stopped the SARs to keep his business.
Here's the thing: Trump wouldn't have even known if Deutsche Bank filed SARs. Problems would've only arisen if the SARs were so suspicious they prompted a criminal investigation.
Here's the thing: Trump wouldn't have even known if Deutsche Bank filed SARs. Problems would've only arisen if the SARs were so suspicious they prompted a criminal investigation.
