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Regulators fine big banks for "weak controls". To show that they have "strong controls", they have to show quantitative data. Now, every bank is engaged in one-

Regulators fine big banks for "weak controls". To show that they have "strong controls", they have to show quantitative data. Now, every bank is engaged in one-upmanship. Since we don't have data on the number of account closures, we should look at SAR/CTR statistics provided by FinCen. Every year, SAR numbers go up by 20%; that's because banks fill SARs with "transaction with no apparent economic, business or lawful purpose". Just gamify SAR reports with vague stuff.

armada651 3y ago
Do you have evidence such quotas exist or that banks are competing on SAR numbers? This all seems like wild conjecture if there's nothing to back it up.
- raincom 3y ago
  https://www.bankersonline.com/ https://www.bankersonline.com/ is a place where people working for banks in BSA compliance, hang out. Based on my reading of that forum, there is a push from BSA auditors to file more and more SARs. Also, anon comments like the following from an old NYT article validate what I see publicly on bankersonline dot com. Also look at another poster's comment: https://news.ycombinator.com/item?id=38158017 https://news.ycombinator.com/item?id=38158017 "Banks are under tremendous pressure by regulators to file a certain amount of SARS (as a ratio of overall transaction activity, which is determined by the regulator - regulators have a secret bogey for each bank). A shortfall from the number expected by the regulators for a bank will result in the bank being penalized by the regulator as having an inadequate BSA program (even if the bank compliance staff reviewed the activity and didn’t find anything worth SAR reporting on). If the bank fights this censure for not filing enough SARs the arbiter of justice is the Administrative Law Judge (ALJ) department of the FDIC or OCC. They rule in favor of the regulators over 99% of the time.) For example California Pacific Bank- a tiny bank serving the Chinese trading community with 200 customers and 500 accounts - was persecuted for more than 5 years for not filing enough SARs, it’s hearing with the ALJ is on YouTube. Even though racist anti Chinese comments by the regulators were unearthed in depositions, the ALJ ruling still went against the bank. Furthermore, banks are required to review ongoing activity of SAR’d customers and file follow up SARs if the “typology” of suspicious activity continues. Bank BSA policies have the requirement that repeat SAR subjects will need to have their accounts closed. Most banks therefore just file SARS on anything that matches a typology and close accounts- that’s just how the BSA regulatory system works.” [1] [1] https://www.nytimes.com/2023/04/08/your-money/bank-account-suspicious-activity.html#commentsContainer https://www.nytimes.com/2023/04/08/your-money/bank-account-s...
  - BLKNSLVR 3y ago
    Goddam fuck that's depressing. Putting the BS into BSA. No wonder shit doesn't work the way it should. Reporting on numbers and percentages rather than actual incidences with audit trails leading to shell companies and tax havens and opaque offshore ownership structures. Because that takes time and effort that meaningless "numbers and percentages" don't require whatsoever. Automation scaling is the jackboot stamping on the human face.
raverbashing 3y ago
That sounds like the kind of idea SBFs parents push in their jobs

armada651 3y ago

Do you have evidence such quotas exist or that banks are competing on SAR numbers? This all seems like wild conjecture if there's nothing to back it up.

raincom 3y ago
https://www.bankersonline.com/ https://www.bankersonline.com/ is a place where people working for banks in BSA compliance, hang out. Based on my reading of that forum, there is a push from BSA auditors to file more and more SARs. Also, anon comments like the following from an old NYT article validate what I see publicly on bankersonline dot com. Also look at another poster's comment: https://news.ycombinator.com/item?id=38158017 https://news.ycombinator.com/item?id=38158017 "Banks are under tremendous pressure by regulators to file a certain amount of SARS (as a ratio of overall transaction activity, which is determined by the regulator - regulators have a secret bogey for each bank). A shortfall from the number expected by the regulators for a bank will result in the bank being penalized by the regulator as having an inadequate BSA program (even if the bank compliance staff reviewed the activity and didn’t find anything worth SAR reporting on). If the bank fights this censure for not filing enough SARs the arbiter of justice is the Administrative Law Judge (ALJ) department of the FDIC or OCC. They rule in favor of the regulators over 99% of the time.) For example California Pacific Bank- a tiny bank serving the Chinese trading community with 200 customers and 500 accounts - was persecuted for more than 5 years for not filing enough SARs, it’s hearing with the ALJ is on YouTube. Even though racist anti Chinese comments by the regulators were unearthed in depositions, the ALJ ruling still went against the bank. Furthermore, banks are required to review ongoing activity of SAR’d customers and file follow up SARs if the “typology” of suspicious activity continues. Bank BSA policies have the requirement that repeat SAR subjects will need to have their accounts closed. Most banks therefore just file SARS on anything that matches a typology and close accounts- that’s just how the BSA regulatory system works.” [1] [1] https://www.nytimes.com/2023/04/08/your-money/bank-account-suspicious-activity.html#commentsContainer https://www.nytimes.com/2023/04/08/your-money/bank-account-s...
- BLKNSLVR 3y ago
  Goddam fuck that's depressing. Putting the BS into BSA. No wonder shit doesn't work the way it should. Reporting on numbers and percentages rather than actual incidences with audit trails leading to shell companies and tax havens and opaque offshore ownership structures. Because that takes time and effort that meaningless "numbers and percentages" don't require whatsoever. Automation scaling is the jackboot stamping on the human face.

raverbashing 3y ago

That sounds like the kind of idea SBFs parents push in their jobs