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I work at a bank, and we get training on this regularly. One of the main reasons FinCEN requires strict confidentiality on SARs is to not tip off the account o

I work at a bank, and we get training on this regularly. One of the main reasons FinCEN requires strict confidentiality on SARs is to not tip off the account owners that they're being watched/investigated. Investigators will often monitor the accounts to gather enough evidence to prosecute them or to gain intel into broader criminal networks. Regulators also rightfully don't want money launderers to know the playbook and tactics they use to track down these networks. The secrecy also protects bank employees. If you're a compliance department worker that's reporting on potential criminal activities of terrorists or a criminal network to the authorities, and you think there's a risk you'll be outed, you might be less willing to submit the SAR.

adrr 6y ago
SARS get generated all the time. Any large movement of cash will generate a SARs. That multi million dollar wire from an escrow account after your startup had liquidity event generated a SARs. What do you think the false positive rate of a SARS report it? 99%? 1 out of 100 SARS reports are actual criminal activity.
- ceejayoz 6y ago
  > Any large movement of cash will generate a SARs. No. It will generate a CTR. It may generate a SAR.
  - adrr 6y ago
    I should clarify, any large transfer to an individual that hasn’t demonstrated access to large amount of capital will generate a SARS. If your not a private client at your bank and you get a $10mm wire will more than likely will generate a SARS and lots of phone calls from the compliance dept at the bank. That like the text book definition of a suspicious transaction. Low balance accounts getting large transfers.
op03 6y ago
This a regulator leaking the data. Not a bank employee leaking the data. Why would they leak it? Cause they know the system is fubar. The simple question to ask is how many people are needed to monitor the system. Now you have one clown after another saying the banks file zillions of reports every day. Thats not the issue. Someone has to monitor all that. And when that someone realizes they arent making a dent, given the volumes, they get sick of the pointlessness and leak the DB. This is going to keep happening. Swiss leaks, Panama papers, libor etc etc We have learnt how to scale things up over the last 20 year exponentially. But oversight can't scale exponentially. It's unsustainable and pressure will build to ridiculous levels on regulators and law enforcement.

adrr 6y ago

SARS get generated all the time. Any large movement of cash will generate a SARs. That multi million dollar wire from an escrow account after your startup had liquidity event generated a SARs. What do you think the false positive rate of a SARS report it? 99%? 1 out of 100 SARS reports are actual criminal activity.

ceejayoz 6y ago
> Any large movement of cash will generate a SARs. No. It will generate a CTR. It may generate a SAR.
- adrr 6y ago
  I should clarify, any large transfer to an individual that hasn’t demonstrated access to large amount of capital will generate a SARS. If your not a private client at your bank and you get a $10mm wire will more than likely will generate a SARS and lots of phone calls from the compliance dept at the bank. That like the text book definition of a suspicious transaction. Low balance accounts getting large transfers.

op03 6y ago

This a regulator leaking the data. Not a bank employee leaking the data. Why would they leak it? Cause they know the system is fubar. The simple question to ask is how many people are needed to monitor the system. Now you have one clown after another saying the banks file zillions of reports every day. Thats not the issue. Someone has to monitor all that. And when that someone realizes they arent making a dent, given the volumes, they get sick of the pointlessness and leak the DB. This is going to keep happening. Swiss leaks, Panama papers, libor etc etc We have learnt how to scale things up over the last 20 year exponentially. But oversight can't scale exponentially. It's unsustainable and pressure will build to ridiculous levels on regulators and law enforcement.