Thread by @ninaandtito

OK you guys-it's time we talk about Suspicious Activity Reporting, and Anti-Money Laundering (AML) in general.
Because we are DEFINITELY going to be hearing a lot more about this. law.cornell.edu/cfr/text/12/21…

Financial Institutions are required to report suspicious activities to FinCEN.
The onus of reporting is ON THE BANKS.

I repeat: It's the Financial Institution's responsibility to file the report.
Sometimes, the banks are corrupt, or inept, and SAR's don't get filed properly. They DO get in trouble for this, IF they get caught.
For example:
complianceweek.com/blogs/enforcem…

For example: bloomberg.com/news/articles/…

For example:

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FOR EXAMPLE:

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However! Suspicious Activity Reporting IS NOT the only Anti-Money Laundering tool we have.
Our LAWS also mandate reporting of EVERY $$ TRANSACTION OVER $10,000.
Every. Single. Transaction. Over. $10K. Goes. Into. A. Database. (there are some exemptions) ffiec.gov/bsa_aml_infoba…

This means that ANY transactions where Michael Cohen or Donald Trump or one of their mobster shitbag friends sent someone >$10K IS IN A DATABASE. You can see what info goes in in the second screenshot.

Is there less info in a regular $10k transaction report than their would be in a Suspicious Activity Report? Yes. SARs require a lot more info. Here's a SAR form: fdic.gov/formsdocuments…

The $10k and higher currency transactions reports are called CTRs and they are e-filed.
ffiec.gov/bsa_aml_infoba…

We ALSO have other Anti-Money Laundering tools, like KYC: Know Your Customer, thanks to the Patriot Act. fincen.gov/resources/stat…

(WHICH WE HAVE SINCE EXPANDED TO REAL ESTATE TRANSACTIONS)

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(Were I a betting woman (and I am) I'd bet KYC will soon be expanded to ART in USA, as has already been done in Europe)

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Anyhoo: SARs are not the end-all be-all of financial transaction reporting. If someone removed those SARs nefariously, the transaction data exists in many other places too.
Like, in banks' own CTR/SAR/account histories (sure, subpoenas are needed but...we gotta lotta subpoenas).

Or in people's tax filings (and if $$ not in ppl's tax returns, then they're gonna get in trouble).
Or in the CTR database.
And guess who can find that data?
FinCEN DEATH ROBOT OF DEATH, aka America's Sweetheart, IRS-CI (h/t @ericgarland)
#FinCENgonnaGetYa
irs.gov/pub/foia/ig/ci…