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TheSARActivityReviewTrendsTips &Issues
Published under the auspices of the Bank Secrecy Act Advisory Group
Issue 5
February 2003
Table of Contents
Introduction…………………………………….……………….....……1
Feedback Form………….…………………………………………...….3
Section 1 – Suspicious Activity Report Statistics………...………....…5
Section 2 – Trends and Analysis……………………………....…..…..17
Section 3 – Other SAR Analysis Issues………….….……..........……..25
Section 4 – Law Enforcement Cases……………….……....….......…..51
Section 5 – Tips on SAR Form Preparation & Filing…….............….55
Section 6 – SAR News Update………….....……………….........……..61
Section 7 – Issues and Guidance………………………...……..............65
Section 8 – Industry Forum…..........…………………………..…...…..69
Appendix 1 – Characterization of Suspicious Activity byStates and Territories by Year…………………....................................72
Introduction
The SAR Activity Review-Trends, Tips and Issues is a product of continuingdialogue and close collaboration among the nation's financial institutions, lawenforcement officials, and regulatory agencies to provide meaningful informationabout the preparation, use, and value of suspicious activity reports (SARs) filed byfinancial institutions.
Significant topics presented in this issue include terrorist financing methodsthrough Informal Value Transfer Systems (IVTS) such as hawalas, as well asthrough non-profit organizations. Also, the money laundering vulnerabilities andindicators of suspicious activity are identified for certain financial institutions thatmay, in the future, be subject to anti-money laundering program rules required bySection 352 of the USA PATRIOT Act. Those institutions include travel agencies,automobile and boat dealers, pawnbrokers, life insurance companies, and certainsegments of the securities industry. Additionally, information concerning the newPatriot Act Communication System (PACS) is provided in the Issues andGuidance Section of this publication.
This publication reflects the recognition of relevant government agencies and thenationís financial institutions of the desirability of a continuing exchange ofinformation between the private and public sectors to improve the SAR System.These financial institutions and government agencies include, among others, theAmerican Bankers Association; Independent Community Bankers of America;American Institute of Certified Public Accountants; Securities IndustryAssociation; Futures Industry Association; Non-Bank Funds Transmitters Group;Federal Reserve Board (FRB); Office of the Comptroller of the Currency (OCC);Federal Deposit Insurance Corporation (FDIC); Office of Thrift Supervision(OTS); National Credit Union Administration (NCUA); Federal Bureau ofInvestigation (FBI); U.S. Department of Justiceís Criminal Division and AssetForfeiture & Money Laundering Section; U.S. Department of Treasuryís Office ofEnforcement; U.S. Customs Service (USCS); U.S. Secret Service (USSS);Internal Revenue Service (IRS); and the Financial Crimes Enforcement Network(FinCEN).
The SAR Activity Review is published semiannually. The previous issues werereleased in October 2000, June 2001, October 2001, and August 2002. Analytic
1
reports, issue papers, and other publications related to, or resulting from,information contained in the SAR Activity Review may be published separately.
Questions, comments, and other feedback concerning the SAR Activity Review arewelcome. A feedback sheet is included on the next page. Comments may also beaddressed to either or both of the SAR Activity Review project co-chairs:
John J. Byrne David M. VogtSenior Counsel and Executive Associate DirectorCompliance Manager Office of Regulatory PolicyAmerican Bankers Association Financial Crimes Enforcement1120 Connecticut Ave., NW Network (FinCEN)Washington, DC 20036 (703) 905-3525 (phone)(202) 663-5029 (phone) (703) 905-3698 (fax)(202) 828-5052 (fax) [email protected]@aba.com
2
3
Feedback FormFinancial Crimes Enforcement Network - U.S. Department of the Treasury
Your feedback is important and will assist us in planning future issuesof the SAR Activity Review. Please take the time to complete thisform. Thank you for your cooperation.
A. Please indicate your level of satisfaction with each section of the SAR ActivityReview.
1=Not Useful, 5=Very Useful
a. SAR Statistics 1 2 3 4 5b. Trends and Analysis 1 2 3 4 5c. Other SAR Analysis Issues 1 2 3 4 5d. Law Enforcement Cases 1 2 3 4 5e. Tips on SAR Form Preparation and Filing 1 2 3 4 5f. SAR News Update 1 2 3 4 5g. Issues and Guidance 1 2 3 4 5h. Industry Forum 1 2 3 4 5
B. How do you use this report? (Check all that apply)
a. Training _________b. Background information resource _________c. Analytic tool _________d. Increase management awareness _________e. Comparison of statistics _________f. Make changes to your compliance program _________g. Audit/exam preparation _________h. Other (identify) _________
C. With whom have you shared the SAR Activity Review? (Check all that apply)
a. Your staffb. Your colleaguesc. Senior managementd. Board/audit committee
D. Have you discussed the SAR Activity Review at management meetings? [ ] Yes [ ] No
E. How did you receive the SAR Activity Review?
a. At the ABA/ABA Money Laundering Enforcement Seminar ______b. On an agencyís website ______c. From a law or accounting firm ______d. Other (identify) ______
4
F. Which of the following best describes your job position? (Check one)
a. [ ] CEO/COO d. [ ] Operations g. [ ] Securityb. [ ] Compliance e. [ ] Legal h. [ ] Governmentc. [ ] Risk Management f. [ ] Audit i. [ ] Other______
G. Which of the previous issues have you read? (Check all that apply)
[ ] October 2000 [ ] June 2001 [ ] October 2001 [ ] August 2002
H. Any Additional Suggestions or Comments?__________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________
Thank you for your feedback.
Send your Feedback Form to:
FinCEN Office of Strategic AnalysisFax [email protected]
OR
American Bankers AssociationFax [email protected]
200113,76714,66016,08415,35716,33514,38716,82319,20314,28320,57120,44421,624
January February MarchAprilMayJuneJulyAugustSeptemberOctoberNovemberDecemberSubtotal
Total Filings
1996---
2,1704,4046,0706,9076,5676,9387,4745,0296,510
52,069
19976,1235,5196,8507,1846,754 6,6967,1756,3327,5617,4395,9607,604
81,197
19986,8327,0558,9388,0577,409 8,737 8,7578,5327,5778,1657,8488,614
96,521
19998,6219,949
11,4929,478
10,400 10,956 8,518
10,4848,4719,843
11,24311,050
120,505
200013,39913,63415,15411,49913,674 13,963 12,61114,11113,32113,14814,43713,769
162,720
Exhibit 1SAR Filings by Year and Month
Number of Filings
940,782
203,538
200219,42417,88125,03719,24927,31316,59026,60022,43324,57125,134
224,232
5
Section 1Suspicious Activity Report StatisticsApril 1, 1996 through October 31, 2002The following statistics1 relate to SARs filed since April 1996 by depositoryinstitutions (i.e., banks, thrifts, savings and loans, and credit unions). A small partof the total volume relates to reports filed by affiliates of depository institutions or,in some cases, filed voluntarily by money services businesses (MSBs) prior to2002, and by brokers and dealers in securities who are not affiliated with banks, orgaming businesses that, during this time frame, were not yet required under theBank Secrecy Act (BSA) to file SARs.
Note: SAR statistical data is continuously updated as additional reports are filed andprocessed. For this reason, there may be minor discrepancies between the statisticalfigures contained in the various portions of this report or in previous reports.
1 Statistics generated for this study were based on the Document Control Number (DCN) of each recordwithin the SAR system. The DCN is a unique number assigned to each SAR submitted. Numericdiscrepancies between total number of filings and the combined number of filings of states and/orterritories are a result of multiple filers listed on one or more SARs.
1,156287
24,350
69454,467
3,5264,4454,360
5941
12,4344,112
90982401
5,7271,638
838838
1,3342,312
3251
2,2493,2204,8803,379
6932,472
284835
3,2211,018
AlabamaAlaskaAmerican SamoaArizonaArkansasCaliforniaColoradoConnecticutDelawareDistrict of ColumbiaFederated States of Micronesia FloridaGeorgiaGuamHawaiiIdahoIllinoisIndianaIowaKansasKentuckyLouisianaMaineMarshall IslandsMarylandMassachusettsMichiganMinnesotaMississippiMissouriMontanaNebraskaNevadaNew HampshireNew Jersey
36265
21,905
20612,631
881422
1,136174
14,195
90727
406109
1,601596267275271500120
0652885
1,1751,000
160638
71194695273949
44559
03,104
33518,143
1,069785
1,429233
3 6,5601,492
80536150
2,763764363287388594186
0937
1,4021,7192,266
251966107249
1,486506
1,530
406131
7 2,392
29722,836
1,475937
1,657274
36,9881,656
52553120
2,863955325362424666189
01,1821,8281,8482,208
2221,139
100315
1,966416
2,377
528157
22,505
43024,995
1,6794,4492,004
2851
7,9132,205
84550186
3,7931,163
427555751902213
21,5372,4772,7462,511
2831,215
152371
2,063573
3,349
689353
103,894
560 43,3042,1464,8733,670
467 3
9,9183,141
73731402
4,7901,349
493520853
1,943241
02,0692,7473,7652,893
5211,590
220615
3,074448
4,197
Exhibit 2SAR Filings by States and Territories
—For the Period April 1, 1996 through October 31, 2002—
State/Territory 1996 1997 1998 1999 2000 2001 2002
6,600
1,034341
710,020
77552,163
5,9233,8285,490
7513
14,4064,657
1061,001
2878,2712,112
7621,2431,5362,422
3723
2,9754,3194,7583,546
6172,307
1982,1652,872
8235,694
6
50223,737
3,238224
414,536
8972,813
203
4,4981,237
530963478
2,03613,426
5834
2,67398
3,0143,989
1731,260
201
New MexicoNew YorkNorth CarolinaNorth DakotaNorthern Mariana IslandsOhioOklahomaOregonOverseasPalauPennsylvaniaPuerto RicoRhode IslandSouth CarolinaSouth DakotaTennesseeTexasU.S Virgin IslandsUnknown/BlankUtahVermontVirginiaWashingtonWest VirginiaWisconsinWyoming
237 5,511
9394322
975395602
120
1,510188166312326569
4,0013
318387
57634771114372
27
2379,6611,621
2155
1,722497
1,11739
02,481
562290563430799
4,9139
20588288
1,2081,733
15455143
28613,297
2,063212
132,198
5031,196
70
2,409440283627547890
6,1581228
1,06861
1,5012,176
161649
54
30717,748
2,366122
332,295
6981,807
20
3,571316503668675993
7,6051726
1,36158
1,5353,124
154755
40
40319,138
2,97822457
3,319813
2,47122
03,535 1,063
495733267
1,55510,119
3219
2,21969
2,0013,362
1821,006
67
Exhibit 2 (continued)
SAR Filings by States and Territories—For the Period April 1, 1996 through October 31, 2002—
State/Territory 1996 1997 1998 1999 2000 2001 2002743
25,5023,049
20465
5,0521,0541,611
111
5,5421,555
9231,1252,9301,732
14,20259
1202,756
1132,8632,665
2411,293
128
7
12345678910111213141516171819202122232425262728293031323334
CaliforniaNew YorkFlorida TexasIllinoisArizonaNew JerseyPennsylvaniaMichiganOhioDelawareConnecticutGeorgiaWashingtonMinnesotaMassachusettsColoradoNorth CarolinaNevadaVirginiaOregonMarylandUtahMissouriLouisianaIndianaTennesseeWisconsinSouth DakotaKentuckyPuerto RicoSouth CarolinaOklahomaHawaii
228,539114,594
62,41460,42430,25828,17024,69623,54620,89120,09719,74619,73918,17017,82017,80316,87816,69916,25415,37712,75611,61711,60111,34610,327
9,3398,5778,5745,8865,6535,5575,3614,9914,8574,759
24.30%12.20%
6.65%6.40%3.20%3.00%2.60%2.50%2.20%2.15%2.10%2.10%1.95%1.90%1.90%1.80%1.75%1.70%1.65%1.35%1.25%1.25%1.20%1.10%
Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%
Exhibit 3Frequency Distribution of SAR Filings Ranked by States
and Territories in Descending Order —For the Period April 1, 1996 through October 31, 2002—
Rank State/Territory Filings Percentage2
(Overall) (Overall)
8
353637383940414243444546474849505152535455565758596061
NebraskaAlabamaKansasNew HampshireIowaArkansasRhode IslandDistrict of ColumbiaMississippiNew MexicoIdahoMaine AlaskaNorth DakotaWest VirginiaMontanaBlank/UnknownWyomingVermontGuamNorthern Mariana IslandsU.S. Virgin IslandsOverseasAmerican SamoaFederated States of MicronesiaMarshall IslandsPalau
4,7444,6204,0804,0573,4753,2973,1902,7782,7472,7151,6551,6461,3931,2441,1791,132
750560544512236190113
3015
64
Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%
Exhibit 3 (continued)
Frequency Distribution of SAR Filings Ranked by States and Territories in Descending Order
—For the Period April 1, 1996 through October 31, 2002—
Rank State/Territory Filings Percentage2
(Overall) (Overall)
9
2 All percentages are approximate.
123456789
1011121314151617181920
BSA/Structuring/Money LaunderingCheck FraudOtherCounterfeit CheckCredit Card FraudUnknown/BlankCheck KitingDefalcation EmbezzlementMortgage Loan FraudConsumer Loan FraudFalse StatementMysterious Disappearance Misuse of Position or Self DealingWire Transfer FraudCommercial Loan FraudDebit Card FraudCounterfeit Credit/Debit CardCounterfeit Instrument (Other)Computer Intrusion4
Bribery/Gratuity
491,988124,141
83,64549,29044,74339,14036,48536,40021,06919,18817,70412,96312,916
7,9677,7675,7814,1252,9981,7771,078
48.20%12.15%
8.20%4.80%4.40%3.85%3.60%3.55%2.10%1.90%1.75%1.27%1.27%
Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%Less than 1%
Exhibit 4Frequency Distribution of SAR Filings
by Characterization of Suspicious Activity in Descending Order—For the Period April 1, 1996 through October 31, 2002—
Rank Violation Type Filings Percentage3
(Overall) (Overall)
10
3 All percentages are approximate.4 Separate box for this violation was added to form TD F 90-22.47 in June 2000. Statistics date from that period.
BSA/Structuring/Money LaunderingBribery/GratuityCheck FraudCheck KitingCommercial Loan FraudComputer Intrusion5
Consumer Loan FraudCounterfeit CheckCounterfeit Credit/Debit CardCounterfeit Instrument (Other)Credit Card FraudDebit Card FraudDefalcation/EmbezzlementFalse StatementMisuse of Position or Self DealingMortgage Loan FraudMysterious DisappearanceWire Transfer FraudOtherUnknown/Blank
21,655 94
9,0782,902
5830
1,1902,405
391219
3,340261
3,2861,880
9521,3181,216
3024,8361,539
Exhibit 5 Frequency Distribution of SAR Filings
by Characterization of Suspicious Activity—For the Period April 1, 1996 through October 31, 2002—
Violation 1996 1997 1998 1999 2000 2001 2002
35,625109
13,2454,294
9600
2,0484,226
387294
5,075612
5,2842,200
1,5321,7201,765
5096,6752,317
47,22392
13,7674,032
9050
2,1835,897
182263
4,377565
5,2521,970
1,6402,2691,855
5938,5832,691
60,983101
16,2324,0581,080
02,5487,392
351320
4,936721
5,1782,376
2,0642,9341,854
7718,7396,961
90,606150
19,6376,1631,320
653,4329,033
664474
6,2751,2106,1173,051
2,1863,5152,225
97211,1486,971
108,925201
26,0127,3501,348
4194,143
10,1391,100
7698,3931,4376,1823,232
2,3254,6962,1791,527
18,31811,908
126,971331
26,1707,6861,5711,2933,644
10,1981,050
65912,347
9755,1012,995
2,2174,6171,8693,293
25,3466,753
11
5 Separate box for this violation was added to form TD F 90-22.47 in June 2000. Statistics date from that period.
For statistical information on the Characterization of Suspicious Activity byStates/Territories by Year see Appendix 1.
18,269
20,089
93,44715,980
3,67411,257
Federal Reserve BoardFederal Deposit Insurance CorporationOffice of the Comptroller of the CurrencyOffice of Thrift SupervisionNational Credit Union AdministrationUnspecified6
5,875
10,339
26,2986,014
2,1411,402
Exhibit 6 SAR Filings by Primary Federal Regulator
—For the Period April 1, 1996 through October 31, 2002—
Regulator Total Filings by Year1996 1997 1998 1999 2000 2001 2002
9,581
14,909
41,4259,122
2,6313,529
10,800
14,735
51,55611,375
2,8465,209
14,656
15,883
64,94612,316
3,0419,663
23,198
28,750
113,26319,560
5,27513,492
24,412
34,240
109,22820,143
6,02410,439
MSB (Bank Form Filings) 0 0 0 0 00 19,746
12
6 Unspecified regulator indicates that the SAR form was filed by a non-bank financial institution that is not directly supervised by one of the five agencies listed above. Such entities that have no regulatory require- ments for the relevant periods that mandate SAR filings include, but are not limited to: money services businesses, insurance companies, and securities broker/dealers who are not affiliated with banks.
Federal Bureau of Investigation Internal Revenue Service U.S. Secret ServicePostal Inspection ServiceU.S. Attorneyís Office U.S. Customs ServiceHigh Intensity Financial Crime Area
Department of TreasuryDrug Enforcement AdministrationDepartment of JusticeOffice of Foreign Assets ControlSocial Security Administration (IG)
Sub-TotalOther Federal Law EnforcementTotal Federal Law Enforcement
RegulatoryFederal Deposit Insurance CorporationFederal Reserve BoardOffice of the Comptroller of the Currency
2,3551,138
894340185
520
5511914
5,044
425,086
2446
17
Agencies 1996 1997 1998 1999 2000 2001 2002 Total
Federal Law Enforcement3,8332,6871,609
610132
620
5618429
9,022
859,107
2629
21
4,1742,1831,223
63684
1010
3023103
11
8,478
1018,579
2527
19
4,7792,1181,060
644106
830
438808
8,857
1038,960
2213
24
4,4931,7301,4011,012
101970
23123
1059
9,004
1089,112
4215
37
7,7332,2592,6541,601
2232393266479776631
15,352
22815,580
153263
102
6,0201,8492,2591,402
3624303232781255351
12,831
81813,649
14034
82
33,38713,96411,100
6,2451,1931,064
649298343143130123
68,588
1,48570,073
432427
302
13
Exhibit 7Direct Referrals of SARs by Financial Institutions to
Law Enforcement7 and Regulatory Agencies—For the Period April 1, 1996 through October 31, 2002—
Exhibit 7 shows the number of times financial institutions that file SARs have alsodirectly referred certain situations to law enforcement officials. The "direct refer-rals" in this edition of the SAR Activity Review have been tabulated by recording acount for each agency to which a direct referral was made. This method is appro-priate since a situation giving rise to a single SAR can be referred to more than oneagency. Such a tabulation accurately reflects the number of times particular lawenforcement agencies received SAR information directly from filing institutions.
Securities & Exchange CommissionOffice of Thrift SupervisionNational Credit Union AdministrationFederal Trade CommissionNational Association of Securities DealersTotal Regulatory
State & Local Law EnforcementCity/Local Police DepartmentCounty/Parish D/A, A/G, or Prosecutorís Office8
State PoliceOther State and LocalTotal State & Local Law Enforcement
Other PendingUnspecified Private Industry9
Foreign Law Enforcement10
FinCEN/DCCGRAND TOTAL
15740
0113
4,407789317
181
89
5,783
8254
295145
11,369
Exhibit 7 (continued)
Direct Referrals of SARs by Financial InstitutionsTo Law Enforcement7 and Regulatory Agencies
—For the Period April 1, 1996 through October 31, 2002—
Agencies 1996 1997 1998 1999 2000 2001 2002 Total
Regulatory (continued)11350
196
6,9781,235
445
295
106
9,059
56184
2774
22418,827
21310
197
7,588938347
263
107
9,243
40164
3369
15318,378
8647
185
7,9941,253
401
289
135
10,072
50234
1286
13119,630
44022
1143
8,9761,533
373
375
129
11,386
31351
1559
18621,283
301568
1578
14,2901,893
500
555
785
18,023
44264
9158
38835,026
2914287
5339
7,908270120
1,369
3,139
12,806
1812421
16227,083
158485024
101,451
58,1417,9112,5033,327
4,490
76,372
2301,532
231418
1,289151,596
7 Some SARs may reference making referrals to multiple law enforcement agencies.8 City, County, or State.9 Includes referrals stating law firm, corporate security, etc.10 Includes referrals made to Interpol.
14
AccountantAgentAppraiserAttorneyBorrowerBrokerCustomerDirectorEmployeeOfficerShareholderOtherNone Indicated
Exhibit 8Relationship of Suspect to Financial Institution
—For the Period April 1, 1996 through October 31, 2002—
Relationship 1996 1997 1998 1999 2000 2001 200252 732921
2,453159
30,698160
5,588495629
9,37816,925
53 1422631
3,231283
49,59588
8,438548381
12,92712,364
39 207
3528
3,727357
62,524122
8,385492390
14,47614,491
51 3588040
4,531514
78,803130
8,632519408
15,21322,206
63 50312245
5,100965
110,463154
10,851565562
21,82225,582
82 52337247
6,1511,512
142,780190
11,693694740
28,25625,969
130 990444
555,7471,584
163,047177
9,364604557
29,72526,818
15
17
Section 2 - Trends and AnalysisHighlighted Topic—Terrorist Financing Methods
The U.S. Departments of the Treasury, Justice, and State have worked together todisrupt and dismantle the sources of terrorist financing. The United States hasalso worked closely with other countries and multilateral organizations to continueto build on its successful record in persuading jurisdictions to adopt anti-moneylaundering and anti-terrorist financing regimes. Due to the successes resultingfrom the blockings of terrorist assets and enhanced cooperation and scrutiny fromlaw enforcement, the financial war on terrorism has entered a new phase. Thisphase is characterized by an increased need to focus on the methods of financingterrorism outside the mainstream financial system. The significance of identifyingand regulating those methods, specifically those involving unlicensed moneytransmitters, is demonstrated by inclusion of Sections 359 and 373 in the USAPATRIOT Act. An understanding by members of the financial community aboutinformal value transfer systems (IVTS), corrupted charitable organizations, andother informal methods for transferring funds across borders and between terroristcells is critical to ensure the reporting of suspicious activity related to thosesystems.
Informal Value Transfer Systems
In November 2002, the Department of the Treasury issued its report on IVTS inits ongoing effort to gain a more complete understanding of the nature of thesesystems.11 The report, required under Section 359, addresses the complexity ofIVTS, provides information for the law enforcement and financial communities,and offers recommendations to further educate those communities about IVTSto help stem their use as potential avenues for money laundering and otherfinancial crime.
IVTS is a term used to describe money or value transfer systems that operateinformally to transfer money. In the past, some of those informal networks werelabeled by various terms including “alternative remittance systems” and“underground banking.” Depending on the ethnic group, IVTS are called by a
11 See Report to Congress in Accordance with Section 359 of the USA PATRIOT Act, available onFinCEN's website, www.fincen.gov, USA PATRIOT Act Info.
18
variety of names including, for example, "hawala" (Middle East, Afghanistan,Pakistan); "hundi" (India); "fei ch'ien" (China); "phoe kuan" (Thailand); and"Black Market Peso Exchange" (South America).
U.S. citizens and persons residing in this country, who are from nations where theuse of IVTS is commonplace, employ the system for various reasons. In countrieslacking a stable financial sector or containing substantial areas not served byformal financial institutions, IVTS may be the only method for conductingfinancial transactions. For example, foreign aid money going to Afghanistan isbeing disbursed through IVTS due to a lack of a banking infrastructure in thatcountry. Individuals and organizations often use IVTS due to inadequate paymentsystems, foreign exchange or capital controls, or because the formal financialsector is not readily accessible, is significantly more expensive, or is more difficultto navigate.
Indicators of the Misuse of Informal Value Transfer Systems in TerroristFinancing
While the majority of IVTS activity is legitimate in purpose,12 some of thesesystems have been used to facilitate the financing of terrorism. The very featuresthat make the systems attractive to legitimate customers — efficiency,convenience, trust, speed, anonymity, and the lack of a paper trail — also appeal toterrorists and terrorist organizations. Also, criminals use the networks to launderdirty money, make illicit payments, and commit other offenses such as taxevasions and customs violations.
The following activity may be suspicious and indicate misuse of IVTS.
• Transactions divergent from the normal activity (or expected low income)of a business entity or customer including:
! sudden influxes of activity and/or unexplained funds deposits;
! high volumes of financial transactions in comparison with those ofother same scale businesses located and operating in the area (e.g.,
12 IVTS traditionally serves the purpose of remitting funds of expatriate communities to their home countries.
19
grocery stores; travel agencies; boutiques; import/exportbusinesses; shipping and trading companies; restaurants; jewelrystores or businesses; textile stores or businesses); or
! large and/or mixed deposits of cash and monetary instruments,inconsistent with the expected type of transactions for the business.
• Unusually high levels of cash shipments detected in conjunction with asmall business operation;
• Transactions involving unusual business trade connections (e.g., smallscale auto parts dealer sending aggregate wire transfers to a precious metaldealer or agricultural importer);
• Separate (or lack of) records kept for certain clients and/or largetransactions;
• Account activity involving only deposits and one-way wire transfers;
• Varying methods of funds delivery and/or collection;
• Unusually high volume or patterns of incoming express/priority mail.
Many uncertainties and complex issues are associated with this segment of thefinancial industry, and additional indicators of suspicious activity may beidentified in the future. The Treasury Department will, therefore, work closelywith law enforcement, regulators, and the financial community to gain a completeunderstanding of these informal networks and how they interact with the moreformal financial industry.
Hawalas
FinCEN closely examined the workings of the hawala system, a widely used formof IVTS. The system works by transferring money without actually moving it.The basic hawala transaction involves a sender, two trusted intermediaries, and arecipient. For example, a U.S. resident who wants to send money to a friend inanother jurisdiction [Country B] would give it to a U.S. hawaladar,13 who typicallyprovides the sender with a specific code or other identification mechanism. The
13 The term hawaladar refers to a hawala dealer or provider of hawala money transfer services.
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U.S. hawaladar then contacts a local hawala operator in Country B by telephone,fax, or e-mail and the sender contacts the intended recipient to convey thedesignated code. The local hawaladar in Country B then delivers the specifiedfunds to the recipient upon presentation of the code. The hawaladar charges a flatfee, commission, or may alternatively or in addition, profit from the exchange ratedifferential between the official and black market price of U.S. dollars in CountryB. The accounts between the two operators may be settled in various waysincluding compensatory payments (i.e., when someone from Country B sendsmoney to the United States), conventional wire transfers or checks, physicalmovement of money (by courier), invoice manipulation or other trade-basedmechanisms, and the trade/smuggling of gold and precious gems.
The USA PATRIOT Act strengthened our governmentís ability to disrupt themovement of funds and, together with existing statutes, provided additionalstatutory basis for prosecuting terrorist financing-related offenses connected to theuse of hawalas and other IVTS.
Specifically, 18 U.S.C. §1960 was amended to tighten the prohibition againstknowingly conducting any "unlicensed money transmitting business." Theprohibition against operating any such business without an appropriate statelicense was amended to state that this prohibition exists "whether or not thedefendant knew that the operation was required to be licensed" or knew thatoperation without such a license was a criminal offense. This means thatignorance of the law cannot be raised as an excuse.14 In addition, the scope of§1960 was expanded to include any business, licensed or unlicensed, that involvesthe movement of funds that the defendant knows were derived from a criminaloffense, or were intended "to promote or support unlawful activity. "
The USA PATRIOT Act also created a new provision, codified in 31 U.S.C.§5332(a), that makes it an offense for any person, with the intent to evade acurrency reporting requirement under Section 5316, to conceal more than $10,000in currency in any fashion, and to transport, or attempt to transport, such currencyinto or out of the United States. This provision also provides for criminalforfeiture of property involved in the offense, including a personal money
14 However, this amendment did not apply to the prohibition in the statute against operating a moneytransmitting business without registering (when required to do so) with FinCEN. FinCEN has identifiedthis discrepancy to Congress. See Report to Congress under Section 359 of the USA PATRIOT Act.
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judgment if directly forfeitable property cannot be found, and the defendant doesnot have sufficient substitute assets to satisfy the forfeiture judgment.
Non-Profit Organizations
Those persons who finance terrorism have used certain charities and non-profitorganizations designed to siphon off money from humanitarian purposes andfunnel it to support terrorism. Contributors are led to believe they are donatingto good humanitarian causes when, in reality, some or all of the donations arediverted for terrorist funding. In response to this problem, law enforcementofficials in the United States have acted to block assets of non-profitorganizations suspected of having ties to terrorist organizations and prosecute,where possible, those responsible for diverting funds from charitable purposes.15
Additionally, in November 2002, a document entitled "U.S. Department of theTreasury Anti-Terrorist Financing Guidelines: Voluntary Best Practices for U.S.-Based Charities" was published to assist U.S.-based charities in avoiding beingused in terrorist financing schemes.16
A FinCEN Advisory will be published in the near future to further address the useof IVTS and non-profit organizations in terrorist financing.
SARs Filed That Refer to Terrorism(March 2002 through September 2002)
FinCEN continued to examine the SAR database to determine the extent to whichSARs have been filed relating to terrorism. Searches were conducted for certainkeywords in the narrative portion that included: terror, terrorism, terrorist(s),September 11(th), 9/11 9/11/01, World Trade Center (WTC), Pentagon, controllist, watch list, hijacking(s), and hijacker(s). Another search involved querying theviolation field. The terms searched in the "Other" violation field included thewords: terrorist(s) and terrorism.
Between April 1, 2002 and September 30, 2002, 717 SARs were filed thatcontained references to terrorism or terrorists. The following chart representsSARs filed pertaining to terrorism for the 13-month period, commencingSeptember 1, 2001 and ending September 30, 2002.
15 Drawn from Contributions by the Department of the Treasury to the Financial War on Terrorism - Fact Sheet, September 2002.16 This document is available through the Department of the Treasuryís website, www.ustreas.gov.
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As shown in the above chart, the number of filings began to steadily declinefollowing a series of spikes between October 2001 and May 2002.
Listed below is more information about these SARs that reference terrorism.
• Seventy-three financial institutions, including six foreign banks licensed toconduct business in the United States, filed SARs.
• The suspicious activity reported in the SARs occurred in 29 states and theDistrict of Columbia.
• Violation amounts ranged from $0 to $48 million.
• Financial institutions indicated that 113 (15.76%) SARs were referreddirectly to law enforcement. (Box 40 was checked on the SAR.)
Most of the SARs filed (531 or 74.05%) were the result of apparent matches ofnames on the Office of Foreign Assets Control (OFAC) and FBI watch lists, namesgleaned from media reports, and as a result of subpoenas issued by lawenforcement.
The activity cited in the SARs remained consistent with the activity described inIssue 4 of the SAR Activity Review (August 2002). The activity included wiretransfers predominantly to and from Middle Eastern countries, the use ofAutomated Teller Machines (ATMs), and large cash transactions.
One hundred and fifty-three (21.33%) SARs were filed as the result of reviews ofaccounts with foreign indicators, unusual account activity, or unusual relationships
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446
324
215292
112
241
141
312
114 10242 24
050
10 0150
2 0 02 503 0 03 504 0 04 5050 0
Sep' 0 1
Oct' 0 1
N o v'0 1
D ec' 0 1
Jan' 0 2
F eb' 0 2
M ar'0 2
A pr' 0 2
M ay' 0 2
Jun'0 2
Jul' 0 2
A ug' 0 2
Sep' 0 2
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that were not typical for a particular type of account. The focus of those SARsincluded:
• charitable organizations and Islamic foundations;
• individuals presenting personal identification from such countries as Iraq,Afghanistan and certain West Asian countries;
• aviation (plane rentals and aviation schools);
• wire activity to or from suspect countries (mostly the Middle East);
• large cash deposits followed by wires out to suspect countries — usuallystructured to avoid reporting requirements; or
• large and frequent ATM activity.
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Section 3 - Other SAR Analysis IssuesThis section of the SAR Activity Review outlines examples and patterns ofsuspicious activity reported in a SAR. The value of this information is thatfinancial institutions reported these activities as suspicious and these examplescan be used to help other financial institutions identify similar suspicious activitiesthat may be occurring within their operations.
Section 352 of the USA PATRIOT Act prescribes requirements for anti-moneylaundering (AML) programs for all financial institutions. The definition of"financial institution" in Sections 5312(a)(2) and (c)(1) of the BSA is broad andincludes institutions already subject to federal regulation such as banks, savingsassociations, credit unions, MSBs, registered securities broker-dealers andfutures commission merchants. The BSA definition of "financial institution"also includes a variety of businesses that have not yet been brought underFinCEN's regulations; indeed, most have never been subject to any federalregulation. Travel agencies, automobile and boat dealers, pawnbrokers, lifeinsurance companies, and segments of the securities industry are some of thenew entities being studied by FinCEN in conformance with the mandate ofSection 352.17
On September 26, 2002, FinCEN issued proposed AML program rules for lifeinsurance companies and unregistered investment companies. In November 2002,these institutions, along with all others not yet subject to a final rule mandatingAML program requirements, were granted an extension of temporary deferral ofthe AML program requirements. In the meantime, FinCEN completed an analysisof SARs filed that related to some of these institutions in order to determine theirmoney laundering vulnerability and to identify possible indicators of suspiciousactivity occurring through those institutions. The following is the result of thatanalysis.
SAR Analysis – Indications of SuspiciousActivity Related to the Travel Industry
The SAR database was searched for terms such as "travel" and "tour" to identifySARs where the suspects were listed as travel agents or travel agencies. Thequeries returned 5,406 unique SARs. A sample of 1,081 SARs was selected atrandom and reviewed, identifying 995 suspects as travel agents or travel agencies.
17 Currently, these entities must file IRS Form 8300, Report of Cash Payments Over $10,000 Received in aTrade or Business. See 31 CFR Part 103.30 for additional information related to this reporting requirement.
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The most frequently reported activity was structuring of currency deposits. Otherfrequently reported activities were deposits of large amounts of currency,structured currency withdrawals, electronic transfer of funds from the suspect'saccount, check fraud, and suspicious currency deposits. The following aresummaries of these types of activities.
The most frequently reported suspicious activity involved structured deposits.
• The majority of the reports described either sequential daily transactionsnear the reporting threshold, or frequent deposits in amounts between$9,500 and $10,000.
• Also reported were multiple same-day deposits at different branches andsame-day deposits at the same branch. Each of the deposits was wellunder the reportable level but daily total deposits exceeded $10,000. TheSAR filer often noted that the bank had reported the transactions by filinga currency transaction report (CTR) for the same-day deposits.
Structured currency withdrawals were also reported.
• Frequent withdrawals of currency in amounts at or just below $10,000were typically conducted by cashing checks written on the customer'saccount.
• Some reports indicated the withdrawal of a specified amount of currency.For example, one report described the withdrawal of $29,000 over threedays where each transaction fell below the reporting limit. The reportnoted that the original funds were provided through an incoming wire fromEast Asia.
• Other reports showed same-day withdrawals in excess of $10,000 thatwere structured among different tellers, different branches, and ATMs sothat no single transaction exceeded the reportable amount.
Suspicious currency deposits were identified.
• Currency deposits by travel agencies were reported as suspicious becausethe aggregate amounts were considered excessive for the filer. Such SARsdescribed a series of deposits over a short period of time that totaled to a"large" amount.
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• Other SARs described ongoing deposits that were considered notcommensurate with the business of the customer.
• In some instances, the filer simply listed a travel agency's currency deposittransactions without any comment as to why such activity was deemedsuspicious on the SAR.
Outgoing wire transfers were sent from travel agencies' accounts.
• Other wire transactions were apparently deemed suspicious because of theamounts involved. For example, one bank reported two domestic wiretransfers that totaled $200,000.
• " Structured" outgoing wires were also reported. Those included small-dollar wires from different persons to a single beneficiary, or multiplesmall-dollar wires from the same person. For example, an MSB reportedseveral remittance agents for numerous small wire transfers to Colombia.(The MSB has a special identification rule for transfers to Colombia thatexceed $1,000.)
Check fraud was another reported violation involving the travel industry.
• The most commonly reported violation was check fraud by personsidentified as travel agents withdrawing funds against worthless checks. Inthose cases, the travel agent deposited checks he knew were worthless andthe bank honored withdrawals against those "uncollected" funds.
• Other common check fraud violations noted were the withdrawal of fundsagainst checks with forged endorsements or maker 's signatures, andcounterfeit checks.
• The cashing of "credit card checks" for accounts that had been closed wasalso reported.
SAR Analysis – Indications of SuspiciousActivity Related to the Automobile RetailIndustry
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A search of the SAR database revealed 1,765 SARs containing the terms "usedcars," "car dealership," "automobile dealership," "automobile sales," or "carsales" in the narrative portion of the SAR. The top three reported violations were:1) BSA /Structuring/Money Laundering (864 SARs); 2) Consumer Loan Fraud(257 SARs); and 3) Check Fraud (175 SARs). Forty-one SARs reported noviolation.
Approximately 350 (20%) of the SARs were reviewed. The following aresummaries of these types of activities.
The most common scenario involved Structuring.
• Individuals working in the automobile retail industry withdrew and/ordeposited cash just under the CTR reporting requirements. Someindividuals did so with unusual frequency within a short period of time(days) at various bank branches within close proximity. The SARsindicated that these transactions were unusual for that type of business.One SAR reported a used car dealer making numerous cash deposits, twicedaily and all under $10,000, at different area bank branches of the samebank. Deposits for one month totaled $750,000. The owner of this cardealership also owns a grocery market. Within one day of each deposit,checks drawn on the car dealership account were written to the grocerymarket. These checks temporarily depleted the dealership account.Another SAR described a small used car dealer located in a poorneighborhood that typically maintained just 10-12 used cars on the lot onany given day. During a two-month period, the car dealer made deposits ofcash and checks totaling over $410,000. The cash deposits were alwaysmade under CTR reporting requirements.
• While attempting to conduct a transaction, some customers altered thecash amount transacted to fall below the CTR reporting requirements wheninformed a CTR would be completed.
• Individuals structured deposits and claimed the funds were derived fromprofits they made, on their own, buying and selling used cars. However,those individuals were not affiliated with any automobile retail business orformally involved in the automobile industry. The SARs described thesuspicious activity but made no mention of similar withdrawals that mayhave been used to acquire the used cars. Suspects claimed to have
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acquired the funds by selling used cars but there was no account activitythat would suggest how they initially obtained the vehicles.
• Customers purchased cars by submitting structured checks/money orders.
Consumer Loan Fraud was also a frequently reported violation.
• Incidents of consumer loan fraud primarily involved the submission offalse or forged statements by loan applicants in their attempt to purchase acar. These applicants were both automobile dealers and retail purchasers.Both dealers and retail consumers submitted loan applications with falsefinancial information, addresses, phone numbers, social security numbers,and forged signatures. Dealers, in applying for a loan, knowinglyunderstated the automobile mileage to the lending institution. Thisfraudulently inflated the value of the vehicle and resulted in a larger thanjustified loan.
• SARs also reported out-of-trust sales, by used car dealers, of vehicles in theirpossession whose acquisition was financed by various financial institutions.Some car dealers altered lien information on duplicate titles in order toobtain a 'clear' certificate of title. These vehicles would then be sold with aloss incurred by the lending institution. The banks advanced payment for thevehicles but failed to receive payment when they were sold.
• Automobile dealers used personal information of their customers, withoutthe knowledge or consent of those individuals, in order to obtain loans.
• SARs also reported the development of relationships between bankemployees and car dealerships. Some situations involved the inappropriatemanipulation of loan applications by bank employees that enabled applicantsfor automobile loans to obtain credit in violation of bank guidelines. Thebank employees earned commissions on these fraudulent loans and theautomobile dealership made money on the sales.
Check Fraud was the third most frequently reported violation.
• SARs reported that checks, later returned for " insufficient funds available,"were used to purchase automobiles from various car dealerships.
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• Some SARs reported the theft of checks from car dealerships and thenfraudulently negotiated by unauthorized individuals, in some cases by formeremployees.
• Other reports indicated that stolen, forged, and counterfeit checks wereused to make payments on vehicles at various dealerships.
• Forged reproductions of a bank's counter-checks were made payable to aused car dealer located in a Gulf State. It is believed that these checkswere computer generated.
Identity Theft was also reported.
• Individuals used someone else's social security number and personal datain order to obtain a car loan in that person's name. Fake identification(driver's license) was also used and forged signatures were employed.Some SARs reported that employees of the automobile dealerships wereaware of this fraud. One incident involved a car salesman providingcustomers a "reference number" so they could qualify for the loan. This"reference number" appeared to be someone else's social security number.
• An unknown suspect established fraudulent bank accounts using theidentities of numerous individuals. The only connection establishedbetween the victims was that each of them purchased automobiles from thesame automobile dealership. The suspect deposited counterfeit checks intothese accounts. The suspect then withdrew funds from these accounts viadebit cards. The cash was then used to purchase postal money orders.
Commercial Loan Fraud also occurred involving automobile dealerships.
• Banks advanced loan funds to car dealers via floor plan lines of creditsecured by the automobiles in inventory. This collateral was later sold,out-of-trust, and the proceeds were not applied to the loan, thus creating aloss for the lender.
• SARs reported that multiple suspects applied for used vehicle loans via theinternet. After normal screening, the loans were approved and drafts weresent. These funds were intended to purchase used cars. No payments werereceived on the loan and attempts to repossess the vehicles were futile.Vehicle Identification Numbers (VIN) given were found to be non-existent.Attempts to locate the suspects failed. One SAR reported that the NewJersey State Police are currently investigating approximately 100 cases ofthis type of fraud.
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Check-Kiting schemes were also reported. Owners of car dealerships wereutilizing the float by writing checks on various accounts at different banks.
SAR Analysis – Indications of Suspicious ActivityRelated to the Boat/Yacht Retail Industry
A search of the SAR database revealed 61 SARs containing the terms "boatsales," "boat dealership," "yacht sales," or "yacht dealership" in the narrativeportion of the SAR. The top three reported violations were: 1) BSA/Structuring/Money Laundering (28 SARs); 2) Consumer Loan Fraud(14 SARs); and 3) Commercial Loan Fraud (12 SARs). One SAR reported noviolation. Violation amounts ranged from $0 to $28,500,000. Twenty-sevenSARs reported a violation amount between $10,000 and $99,999. TwentySARs were between $100,000 and $999,999. The violation amount on eightSARs exceeded $1,000,000. A total of 13 SARs were forwarded directly tofederal, state or local law enforcement or regulatory authorities. The followingare summaries of these types of activities.
The most common scenario involved Structuring.
• Individuals working in the boat retail industry withdrew and/ordeposited cash just below the CTR reporting requirements. Someindividuals conducted these transactions with unusual frequency withina short period of time (days) at various bank branches within closeproximity. The SARs indicated that the transactions were unusual forthat type of business. It was noted that many deposits were regularlymade, even during the boat sale off-season. Cash is not typically usedto purchase boats. One boat dealer deposited over $255,000 fromJanuary 2002 to May 2002. Forty-three deposits were made, typicallyranging from $5,000 to $9,000 (none over $10,000). Another SARrevealed that the owners and employees of a particular boat dealerpurchased cashier 's checks, with cash, at a bank with which they hadno relationship, and then deposited the cashierís checks in thedealership's business account at another bank. All transactions fellbelow $10,000 and were, believed by the filer, to be intended to avoidCTR reporting requirements.
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• When informed of CTR reporting requirements, while attempting toconduct a transaction, some customers would alter the cash amounttransacted to fall below reporting requirements.
• Individuals structured deposits and claimed the funds were derivedfrom boat sales.
• Customers purchased boats by submitting structured checks/money orders.
• Customers purchased boats by submitting large, one-time payments (insome cases in excess of $100,000). During a two-month period in 2001, ayacht sales company received $2,685,000 in seven wire transfers from thesame individual located in a Middle Eastern country.
• One internet-based yacht brokerage firm filed a SAR regarding asuspicious acting customer. The customer wished to purchase a $28.5million yacht through the firm. The customerís behavior was erratic andthe deal was never consummated.
Incidents of Consumer Loan Fraud primarily involved the submission of false orforged statements by loan applicants in their attempt to purchase a boat.
Commercial Loan Fraud also occurred involving boat dealerships.
• Several SARs reported boats may have been sold to more than one owner;serial numbers on boats were altered; and boats stored at the dealership/marina by legitimate owners were represented as inventory. Theseviolations were discovered during audits performed by the lender.
• More than one bank financed the same boat (duplicate loans) maintainedby a boat dealer. The invoices on these boats were later found to befraudulent.
• Boat dealers, maintaining large lines of credit, substantially overstated thevalue of their boat inventory. A large portion of the overstatement resultedfrom the out-of-trust sale of boats without forwarding the sale proceeds to
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the banks. It is believed that the borrowers may never have owned boatspledged to the loan.
• Boat dealerships diverted sales proceeds due the financing institution andloans from the financing institution to improper uses.
SAR Analysis – Indications of SuspiciousActivity Related to Pawn Brokers
A search of the SAR database revealed 272 SARs containing the terms "pawnbroker," "pawnbroker," "pawn shop," or "pawnshop" in the narrative portion ofthe SAR.
A total of 326 violations were reported in the 272 SARs (note that a SAR mayindicate no violation, one violation, or multiple violations). The top five reportedviolations were: 1) BSA/Structuring/Money Laundering (52.15%);2) Other (8.28%); 3) Credit Card Fraud (7.97%); 4) Check Kiting (7.36%); and 5)Check Fraud (4.91%). Nineteen SARs (5.83%) reported no violation.
Violation amounts ranged from $0 to $9,000,000. The violation amounts fell intothe following categories: 27.94% reported a violation amount of $0; 24.26% werebetween $1 and $9,999; 31.62% fell between $10,000 and $99,999; 12.87%between $100,000 and $999,999; and 3.31% exceeded $1,000,000.
A total of 40 SARs (14.7%) were forwarded directly to federal, state, or local lawenforcement or regulatory authorities. Of these referrals, 31 SARs (77.5%) werereferred to state and local law enforcement organizations, three SARs (7.5%) werereferred to the FBI, and two SARs (5%) were referred to the IRS.
Two hundred and forty-six SARs (90.4%) were reviewed from the years 1996through 2002. The following are summaries of these types of activities.
The most common scenario involved Structuring.
• Numerous pawnbrokers withdrew and/or deposited cash just falling underthe CTR reporting requirements. Some customers did so with unusualfrequency within a short period of time (days) at various bank brancheswithin close proximity.
• When informed of CTR reporting requirements, while attempting toconduct a transaction, some customers would alter the cash amount
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transacted to fall below reporting requirements. Some individuals walkedaway without completing the transaction.
• Some pawnbrokers structured cash deposits and made large withdrawalsvia checks written for cash on their own accounts.
Possible BSA/Structuring and Check-Kiting violations were found in asignificant percentage of SARs.
• Fifty-seven SARs (21%) involved suspected BSA/Structuring and check-kiting violations. Numerous checks to various individuals and businesses,drawn on the accounts of a number of businesses, were cashed. Thechecks were large in number and amount. The SARs reported it is highlyunusual for an individual to go to a pawnshop to cash checks in such highamounts.
• Check-Kiting schemes were also reported in which individuals wereutilizing the float from writing checks at various banks and pawnshops.
A number of pawnbrokers conducted unusually large cash deposits andwithdrawals, relative to the type of business, at various alternating bank branches.SARs were filed on those pawnbrokers exhibiting a high frequency of this activityrelative to other closely located pawnshops.
Another scenario involved the use of fraudulently obtained or stolen credit cards.
• Stolen credit cards or those obtained fraudulently, via identity theft, wereused to purchase merchandise at various pawnshops.
• Fraudulently obtained credit cards were used to purchase merchandise atnon-pawnshop, retail outlets. This merchandise was later sold for cash atlocal pawnshops.
• In some instances, the owners/managers of pawnshops made purchasesusing fraudulently obtained credit cards.
Several SARs involved stolen, forged, and counterfeit checks.
• Numerous incidents involved the theft and forging of checks subsequentlycashed at pawnshops. Occasionally, forged checks were used to purchasemerchandise at a pawnshop.
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• One incident involved 56 named suspects in a counterfeit check ring thatutilized pawnshops to cash these checks.
• In a few instances, the owner/employee of the pawnshop called the bank toinquire as to the legitimacy of a suspect check. According to one filing,the FBI notified the bank that a particular owner of a pawnshop was thevictim of check fraud.
Commercial Loan Fraud also occurred involving pawnshops.
• Most incidents involved individuals who defaulted on a loan and then soldpersonal property to a pawnshop that had been used as collateral for theloan. In some instances, a court order required the pawnshop to transferthe property to the bank.
• A few pawnshop owners/employees reportedly submitted fraudulentinformation while applying for a loan.
Incidents of embezzlement and theft were also reported.
• Banks reported employee theft of bank or customer property that was laterdiscovered to have been pawned for cash. This property mostly consistedof computer equipment (laptops) or customer property held in safe depositboxes.
SAR Analysis — Indications of SuspiciousActivity Related to Life Insurance
In August 2002, FinCEN conducted an analysis of all SARs submitted bydepository institutions, affiliates of depository institutions, and those voluntarilyfiled by broker-dealers, MSBs, or gaming businesses from the years 1996 through2002 in which activity was reported in the narrative section that could be linked toa set of specific terms related to the insurance industry. This analysis was notconducted to assess the money laundering risks associated with the insurancesector; rather, it was conducted to provide a snapshot of what SAR filers werereporting regarding key terms related to the insurance industry.
A search of the SAR database revealed 1,032 SARs containing the term "lifeinsurance" in the narrative portion of the SAR.
• A total of 97 SARs were filed by eight life insurance companies/providers.
• A total of 1,130 violations were reported in the 1,032 SARs (note that a SARmay report no violation, one violation, or multiple violations.)
• The violation amounts reported in the SARs fell into the following categories:69% - $51 to $99,000; 19.7% - $100,000 to $975,000; and 5.8% - $1 millionto $500 million. [Note: 57 SARs (5.5%) reported no violation amount.]
• The BSA/Structuring/Money Laundering violation totaled 19.2% of all theviolation categories reported.
• A total of 154 SARs (14.9%) were forwarded directly to federal, state orlocal law enforcement or regulatory authorities. Of these referrals, 50SARs (32.5%) were referred to the FBI, 40 SARs (26.0%) were referred tothe Drug Enforcement Administration (DEA), and 30 SARs (19.5%) werereferred to state and local law enforcement organizations.
A sample of 206 SARs (20.0%) was randomly selected and reviewed from theyears 1996 through 2002. The following are summaries of these types ofactivities.
The most common scenario found involved fraud with respect to checks of lifeinsurance companies.
• The principal check fraud involved counterfeit checks. There werenumerous reports of counterfeit checks on the accounts of life insurancecompanies that were deposited into the suspect's bank account. Often, thefalse checks cleared and the suspect transferred the funds before the bankwas notified that the checks were counterfeit.
• Another check fraud involved checks written by life insurance companiesthat were altered by the suspect. Often, the checks were stolen and thesuspect altered the payee, dollar amount, or both. In many cases, thesuspect was able to withdraw funds against these altered checks.
• Blank checks of life insurance companies were also reported as havingbeen stolen and then made out to the suspects for various amounts. Themaker's signature was forged and the suspect deposited the forgedinstrument and withdrew the funds.
• There were also many reported instances of checks that were stolen and thepayee's signature forged by the suspect.
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Another common scenario involved the suspicious transfer of funds to or fromlife insurance companies.
• Financial institution customers made structured cash withdrawals from anaccount funded with the proceeds of a life insurance company check.
• Withdrawals and transfers from accounts funded with the proceeds of alife insurance company check were reported as suspicious. Some ofthese transfers were to persons or accounts located in foreign countries.
• Some financial institution customers made structured cash depositsinto an account and then transferred the funds, by wire or check, to alife insurance company. Other customers made structured cashpurchases of cashier 's checks made out to life insurance companies.
• When informed of the CTR reporting requirements when attempting tocash a check from a life insurance company, customers either reducedthe amount of cash back or demanded to have the transactioncompleted without filing a CTR. Some individuals walked awaywithout completing the transaction.
A significant percentage of SARs that contained the term "life insurance"described various types of loan fraud.
• Borrowers who had pledged life insurance policies as loan securitycashed-out the policies and then defaulted on the loans.
• Credit applicants overstated the cash value of life insurance policies oncredit applications or listed term life policies as whole life policies.
• Borrowers pledged life insurance policies to obtain loans from onefinancial institution while such policies were already the security forloans from other financial institutions.
Life insurance companies were targets of "Nigerian Advanced Fee" scams.There were reports of letters and e-mails from purported former governmentofficials of African countries (Nigeria, South Africa, Sierra Leone, Congo)who were seeking assistance in moving millions of dollars to accounts in theUnited States. The solicitor promised the participant fees up to 35% of theamount to be transferred.
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A number of SARs were filed relating to the embezzlement or theft ofinsurance proceeds by bank employees.
• A bank employee sold an annuity issued by a life insurance company toa bank customer. The customer and his beneficiary both died shortlythereafter. The bank employee then diverted the annuity's death benefit tohimself.
• Several bank officers used bank funds, without proper authorization, topurchase whole life insurance policies on their lives.
• One bank employee conspired with the bank's life insurance agent to havepremium rebates paid to the bank employee instead of the bank.
SAR Analysis – Indications of Activity Related tothe Securities Industry
A small part of the total volume of SARs filed is for reports filed voluntarily18 bybrokers and dealers in securities that are not affiliated with banks. In August2001, FinCEN conducted a study to determine the number of SARs being filedvoluntarily. Between April 1996 and April 2001, securities, investment, andbrokerage services had filed 1,930 SARs of the 572,835 SARs filed.
FinCEN has not performed a full analysis of the SARs that were submittedspecifically by broker-dealers. However, FinCEN's staff conducted an analysis ofall SARs submitted by depository institutions, affiliates of depository institutions,and those voluntarily filed by broker-dealers, MSBs or gaming businesses fromthe years 1996 through 2002. These SARs were identified by searching thenarrative section for key words related to the securities industry (e.g., investmentcompanies, mutual funds, hedge funds, private investment trusts, venture capitalfunds, investment advisers). This analysis was not conducted to assess the moneylaundering risks associated with securities sector; rather, it was done to provide asnapshot of what SAR filers were reporting related to the securities industry.
18 Some broker-dealers have filed SARs for years, either since 1996, pursuant to bank regulatorsí rules forbank holding company affiliates, or since 1989, voluntarily pursuant to guidance issued by the NewYork Stock Exchange and National Association of Securities Dealers. (Note: Effective January 1, 2003,all broker-dealers were required to file SARs.)
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For each of the sets of SARs linked to the terms, an analysis was conducted toidentify baseline statistical information, including the total number of BSAviolations reported; the range of violation amounts; and violation categories. Inaddition, an analysis was conducted to identify the primary types of suspiciousactivity reported by the filing institutions. Due to the large number of SARsidentified for several of the terms, those data sets were sampled to provide aworkable number of significant findings from the narratives. The followingprovides a synopsis of the data related to key terms of the securities industry.
INVESTMENT COMPANIES
Baseline Statistical Information
! The terms "investment company" or "investmentcompanies" were found in 536 SARs.
! Securities broker/dealers filed 13 SARs.
! 630 violations were identified.
! The reported range of violations consisted of the followingamounts:
$700 to $99,000 39.9%$100,000 to $891,000 25.7%$ 1 million to $ 1 billion 25.8%Other amounts 8.6%
! BSA/Structuring/Money Laundering violations accountedfor 49.2% of the violations.
Significant Findings from a Review of 114 Sample SARs
The most common scenario involved the suspicious movement of funds throughwire transfers and checks and cash deposited and withdrawn from investmentcompany accounts.
The wire transfer activity into and out of investment companies indicated thatwires originated from the Philippines, Hong Kong, Macao, Vietnam, Israel,Nigeria, Russia, Japan, Latin America, and Austria. Outgoing wire transfers were
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to the Philippines, United Kingdom, Singapore, India, Vietnam, Indonesia,Thailand, Lebanon, Korea, and the UAE.
Numerous examples cited deposits and withdrawals using a combination of theseactivities, whereby funds were deposited into investment companies' accounts andsoon after (same day or within days), withdrawals were made from the accounts.
Examples of this activity include:
• wire transfers and cash deposited into investment accounts followed bychecks used to transfer funds to other accounts;
• wire transfers received from an investment company and deposited into apersonal account followed by checks used to move the funds to otheraccounts; and
• large cash deposits into personal accounts followed by large-dollar checkswritten to investment companies.
Another common scenario involved the use of structured cash deposits under$10,000 or cash withdrawals under $10,000 involving investment companies'accounts. Financial institutions indicated that the structured cash deposits andwithdrawals did not seem commensurate for an investment company.
• Financial institution customers often made structured cash deposits into anaccount and then used wire transfers or checks to transfer funds into aninvestment company account.
• Structured deposits often occurred on the same day or over several days inthe same week.
• When informed of the CTR reporting requirements, customers eitheraltered or reduced the amount deposited or demanded to have the depositmade without completing a CTR form. Some individuals walked awaywithout completing the transaction.
Other SARs of interest are described below.
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• Seven SARs were filed by financial institutions as a result of mediareporting that the owners of the investment companies were underinvestigation in other countries for fraud and corruption.
• Five SARs were filed relating to September 11th activity and the OFAClist of "specially designated global terrorists" — organizations andindividuals engaged in international terrorism. Two SARs identifiedactivity of investment companies on the OFAC list. Three SARs describedactivity of individuals or entities on the OFAC list that includedtransactions involving investment companies.
INVESTMENT ADVISORS
Baseline Statistical Information
! The terms "investment advisors" or "investment advisers" were found in 128 SARs.
! Securities broker/dealers filed 26 SARs.
! BSA/Structuring/Money Laundering violations accounted for 34(26.6%) of SARs filed.
! Embezzlement-defalcation and misuse of position were cited in20 SARs (15.6%) as the major violation.
Significant Findings from a Review of Sample SARs
Many SARs describe mismanagement of investor funds through variousfraudulent schemes. One particular scheme involved a "collateralized investmentagreement" that offered to pay a specified rate of return for a fixed period andclaimed that it would be fully protected or collateralized by a pool of securitiesequal to the amount of the principal investment. Clients who invested in thisscheme suffered a combined loss of approximately $71 million.
Fifteen SARs filed described three Ponzi/pyramid schemes being operated bynumerous individuals and companies. Over 350 bank customers, whoseinvestments exceeded $26 million, invested in these schemes based on advice oftheir financial advisors.
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Twelve SARs noted check fraud as the main violation. Most of the narrativesdiscuss checks being provided to the advisor for investments in previously agreedfunds, but were never invested or were redirected to other companies without theclient's knowledge.
Three SARs described fraud by the investment advisor assigned to a familycustodian trust. Each advisor had submitted fraudulent bills/fees for payment forservices never rendered or forged documents/checks.
Other SARs include the following scenarios:
• An investment advisory company introduced three accounts to a majorinvestment corporation (broker-dealer). It was later learned that one of theaccount holders utilized an alias when setting up the account and that theaccount was actually for the widow of a deceased Colombian narcoticstrafficker. During the period of December 1995 to February 1999, theaccount was credited with $1.5 million in the form of wire transfers fromU.S. banks and financial institutions and debited $1.4 million via wiretransfer and checks. The monies remaining in the account were transferredto another account in the same alias and another individual. In October1999, the remaining monies were transferred to a third account owned bytwo individuals domiciled in Medellin, Colombia.
• An investment advisor, with a 12-year relationship with a brokeragecompany, wire transferred $3.25 million during a four-month periodthrough a third party. He then requested that the originator's name not beused on the wire transfer record. His explanation for the third partyaccount was that he wanted to "break the trace" between both banks.
• An investment advisor operating in the United States provided fraudulentbrokerage statements to a Canadian client, resulting in a loss in excess of$300 million.
VENTURE CAPITAL
Baseline Statistical Information
! The term "venture capital" was found in 60 SARs.
! Securities broker/dealers filed four SARs.
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Significant Findings from a Review of Sample SARs
The SAR narratives depicted several different scenarios. The most common ofthese scenarios discussed suspicious wire transfers to and from accounts held byventure capital companies.
• Incoming wires originated from Switzerland, France, the United Kingdom,Germany, Liechtenstein, Luxembourg, Poland, Egypt, Israel, China,Taiwan, Hong Kong, Singapore, Barbados, the Bahamas, Guinea, andCanada.
• Outgoing wires were sent to Nicaragua, the Netherlands, and Poland.
• The wire totals were high-dollar amounts.
• Nine of the 22 SARs that discussed wire transfers ranged between$260,000 to $999,962.
• Thirteen SARs had aggregate totals that ranged from just over $1 millionto $16 million.
• Some banks reported that funds for the wire activity appeared structured toavoid CTR reporting requirements.
Six SARs reported various attempted scams perpetrated against a bank.
• Two SARs involved Nigerian scams that attempted to bilk millions ofdollars from the financial institutions under the guise of venture capital.
• Some SARs reported schemes to defraud individuals to allegedly raisestart-up capital by offering high rates of return on investment.
Three SARs described the use of false letters of credit allegedly issued by foreignbanks. When the filing banks attempted to verify the letters, they usually foundthat the foreign bank did not issue the letters of credit. The bearers of the letterswere seeking to invest in venture capital companies.
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Two SARs involved identity theft.
• Stolen bona fides were used to obtain an application into an investment/venture capital company.
• Stolen identity was used in an attempt to secure an indirect loan through aventure capital company.
PRIVATE INVESTMENT TRUST
Baseline Statistical Information
! No SARs contained the term "private investment trust."
! The term "investment trust" appeared in 54 SAR narratives.
! Securities broker/dealers filed eight SARs.
! 61 violations were reported.
! BSA/Structuring/Money Laundering violations accounted for 29% ofSARs filed.
! 51.9% of the SARs were filed in 2001 and 2002.
Significant Findings from a Review of Sample SARs:
The most common activity identified in the narratives involved suspicious wiretransfers, and suspicious checks, cash, and money orders deposited into andwithdrawn from investment trust accounts. The wire transfer activity into and outof investment trust accounts indicated that wires originated from Nigeria,Lebanon, Saudi Arabia, and the Netherlands. Outgoing wire transfers were toSaudi Arabia, Taiwan, and Pakistan.
• Numerous examples cited deposits and withdrawals using a combinationof these activities, whereby funds were deposited into investment company
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accounts and soon after (the same day or within days) withdrawals weremade from the accounts.
• Wire transfers and checks were deposited into an investment trust accountfollowed by wire transfers to other accounts.
• Wire transfers were deposited into an investment trust account followed bycash withdrawals.
Other SARs of interest included the following scenarios.
• A large amount of cash was removed from a safe deposit box anddeposited into a checking account. On the same day as the cash deposit, a"debit memo" of approximately the same cash amount mentioned abovewas taken out of the checking account and placed into an investment trust.The movement of money from the safe deposit box was consideredsuspicious by the financial institution.
• An investment trust account was involved in several instances of allegedfraudulent activities involving investment instruments such as "reportguarantees." The financial institution reported this as a possibleinvestment fraud/advance fee scheme.
HEDGE FUNDS
Baseline Statistical Information
! The term "hedge funds" was found in 17 SARs.
! Securities broker/dealers filed seven SARs.
Significant Findings from a Review of Sample SARs
The most common activity described the use of false statements and possiblefraudulent activities.
• Three narratives described employees/broker dealers misusing theirposition for personal gain. The SARs included insider trading,embezzlement, and a foreign corporation routing its hedge fund accountfunds through the United States before routing to its final destination in
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order to avoid the money laundering identification documentationregulation in the United Kingdom.
• Several instances were reported about the use of false documentation andfalse statements to attempt to open hedge fund accounts. New accountswere declined when the reporting financial institution was unable toconfirm the credentials supplied by requestors.
Some SARs described suspicious wire transfer activity involving hedge fundaccounts, including two that involved international activity.
• Suspicious transactions conducted the same day were reported involving awire transfer sent to a hedge fund account by its managing service. Thewire transfer activity was followed by large cash withdrawals from thehedge fund and from a personal account by a managing service employee.
• Two investment firms wire transferred $2.2 million from their accounts inMassachusetts to their accounts in California; the following day, they wired thefunds to the credit of an individual account at another California financialinstitution. The names for both firms included "hedge fund" and the accountswere opened and closed within a five-day period.
• A Middle Eastern business wire transferred $2.1 million to four offshore hedgefunds accounts, most of which was eventually returned to the U.S. accounts ofthe business and then wire transferred to an account in Switzerland. All wiretransfer activity took place over an approximate two-month period.
Two SARs described financial institutions closing hedge fund accounts due to namesimilarities between their clients and individuals mentioned in the media who aresuspected of laundering money.
MUTUAL FUNDS
Baseline Statistical Information
! The terms "mutual fund" or "mutual funds" were found in 557 SARs.
! Securities broker/dealers filed 86 SARs.
! 631 violations were reported.
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! Violation amounts, ranging from $1 to $50,000, were reported in 223SARs (40%).
! BSA/Structuring/Money Laundering violations accounted for 25.20% ofSARs filed.
! 44.17% of the SARs were filed in the years 2001 and 2002.
Significant Findings from a Review of 92 Sample SARs
The most common scenario described the use of checks that were stolen, altered,and used along with forged signatures to either establish mutual fund accounts orredeem funds.
• Numerous examples were cited of established corporate or individual bankcustomers as fraud victims via theft of corporate or personal checksthrough the U.S. mail system. These checks were later used to establishpersonal checking accounts (with funds later transferred to mutual fundaccounts) or mutual fund accounts. Corporate theft cases often involvedcompany employees with access to company mail. Most other thefts weredetermined to be principally through U.S. Postal delivery sites as well asother family members.
• Numerous examples were cited of recent or low bank account balanceholders using stolen or altered checks, or checks later returned as "non-sufficient funds" to establish mutual fund accounts.
Another common scenario described the use of structured cash deposits orwithdrawals under $10,000 involving mutual fund accounts.
• Bank customers often made structured cash deposits on the same day or onmultiple days during a week, and then used a personal check or purchaseda bank or cashier's check to deposit into a mutual fund account.
• Bank customers deposited checks from a mutual fund account intopersonal checking accounts and would then redeem funds through a seriesof structured withdrawals via the branch or ATM over days or weeks.
• When informed of the CTR reporting requirements when making adeposit, bank customers either altered or reduced the amount deposited ordemanded to have the deposit made without completing a CTR form.
A small percentage of transactions involved suspicious wire transfers to or frommutual fund accounts based either in the United States or abroad.
• Incoming wires into U.S.-based bank accounts often described proceedsfrom "offshore mutual fund accounts" located in countries includingSwitzerland, Brazil, Venezuela, and the Bahamas.
• Outgoing wires from U.S. accounts were sent to locations includingThailand, Cayman Islands, and the Netherlands Antilles.
• Wire transfer aggregate totals were of dollar amounts significantly higherthan the average transaction.
Other SARs of interest included the following scenarios.
• Two bank customers who operated various business investment accountsvalued in the millions of dollars were under investigation by the Securitiesand Exchange Commission for multiple violations of the securities andbanking regulations, including illegal operation of a mutual fund.
• A bank customer operated a convalescent center and deposited $540,000 inpatients' Social Security/Medicare/Medicaid checks. Funds were movedfrom the convalescent center's business account to a personal checkingaccount, and then wired to a personal mutual fund account, then back tothe convalescent center business account.
• A bank customer conducted nearly $2 million in suspect wire transfersusing mutual fund accounts inside as well as outside the United States overa period of several months.
SARs filed by Money Services Businesses
The suspicious reporting requirements of the BSA became applicable to certainMSBs, effective January 1, 2002.19 Money transmitters and issuers, sellers, and
19 See 31 CFR Part 103.20.
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redeemers of money orders and travelerís checks are now required to reportsuspicious activity.
A search of the SAR database from January 1, 2002 through September 31, 2002,revealed 16,692 SARs submitted by MSBs. The MSB SARs were filed by 518separate entities, including both money transmitter companies and/or individualauthorized agents.
Violation amounts ranged from $0 dollars to $705 million (which included anunsolicited e-mail offer for foreign exchange totaling more than $700 million; nocurrency or other monetary instruments were actually involved.) The following isa breakout of violation amounts reported:
Dollar Range Number of Filings Percentage$0 583 3.49%$1 -$9,999 11,374 68.14%$10,000 - $19,999 2,657 15.91%$20,000 - $29,999 737 4.41%$30,000 - $39,999 350 2.09%$40,000 - $49,999 241 1.44%$50,000 - $59,000 353 2.11%$60,000 - $99,999 249 1.49%$100,000 - $999,000 129 Less than 1%Over 1 million 19 Less than 1%
The MSB SARs were filed in 49 states as well as the District of Columbia, Guam,Puerto Rico, Canada, the Dominican Republic, and Japan (by the U.S. NavyExchange.) The following top five state filers (by volume) accounted for 57.33%of all filings:
State Number of Filings PercentageNew York 4,145 24.83%Colorado 2,405 14.40%Arizona 1,908 11.43%California 691 4.13%Florida 425 2.54%
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The MSB SARs referenced 15,235 violations. Often, more than one violation wascited per SAR. In 1,408 (8.43%) cases, the violation field was blank. The topthree reported violations were: BSA/Structuring/Money Laundering - 12,304(80.76%); Other-1,282 (8.41%); and Wire Transfer Fraud - 686 (4.50%).
More than half of the narratives dealt with structured money transfer activity.The majority of those SARs described outgoing wire activity and to a lesserdegree, incoming wires. Outgoing wires were primarily destined for recipients inCentral America (predominantly the Dominican Republic), as well as within theUnited States, the Middle East, and Europe. The typical scenarios involvedmultiple senders to the same recipient, individual senders to multiple recipients ina very short period of time (often within minutes), and an individual remitter to asingle recipient.
Other reported activity dealt with the suspicious purchase of money orders.
• Customers purchased excessive amounts of money orders for noapparent reason.
• The source of cash used for the purchases was unknown.
• Individuals purchased money orders in structured amounts at multiplelocations.
• The purchaser line on the money order was left blank or was illegible.
• The payee and purchaser names on the money order were the same.
Identity theft or fraud was reported in a number of SAR narratives. Oneparticular MSB reported numerous cases of identity theft where the perpetratorobtained the log-in and user ID to access victimsí accounts on-line. Theperpetrator then moved funds to his own accounts or used the victimsí money toeffect wire transfers to a third party.
Most high-dollar violations reported by MSBs dealt with "Nigerian AdvanceFee" scams via unsolicited faxes or e-mails.
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Section 4 - Law Enforcement CasesThis section of the SAR Activity Review provides law enforcement agencies withthe opportunity to summarize investigative activity in which SARs and other BSAinformation played an important role in a successful investigation and/orprosecution of criminal activity. Each issue of the SAR Activity Review includesnew examples based on information received from law enforcement.
SAR Initiates Investigation of Illegal MoneyTransfers to Iran
In February 2002, SAR information provided by an investment account firmrevealed wire transfers in excess of $500,000 originated from an individual'saccount, through a trading company in Dubai, UAE, for transfer to Iran.Investigation disclosed the account holder had made comments to the reportingfirm indicating the money was being wired for investment in Iran, in violation ofthe U.S. embargo.
In April 2002, USCS and IRS agents executed a search warrant on the accountholder's residence, which resulted in the seizure of considerable documentationsubstantiating the allegation, along with several computer systems. Review of thedocuments and records seized identified other bank records revealing the accountholder used other accounts to wire transfer funds from London, England, toDubai, and ultimately Iran. In addition, an account was being used to wire transferfunds to various Iranian individuals in the United States, including one for$50,000, made at the direction of a suspect in Iran. Investigations continue in theUnited States, Hong Kong and the United Kingdom. (Source: U.S. CustomsService)
SARs Lead to Approximately $427,000 BeingSeized From an Unlicensed Money Remitter
Information gleaned from a review of SARs filed by financial institutionsidentified two brothers who are under investigation for operating an illegal moneyremitter business. USCS agents have documented in excess of $12 million beingwired to foreign locations, primarily Singapore and Indonesia, over the past threeyears.
In October 2002, federal agents executed a seizure warrant on a bank accountcontrolled by one of the subjects. Pursuant to the warrant, approximately
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$318,000 was seized. A search warrant was also executed on one of thesubject's residences, where approximately $74,000 in currency, along withnumerous documents related to the operation of a wire remitter service wasseized. Approximately $35,000 was seized from the other subject's bankaccount.
Both subjects admitted to operating a hawala-type business from the residence.(Source: U.S. Customs Service)
SARs Lead to $3 Million Being Seized From anUnlicensed Money Remitter
In January 2002, an investigation was initiated, subsequent to receiving SARs,into the operation of an unlicensed money remitter.
A foreign bank account, containing approximately $3 million, was frozen at therequest of USCS agents. A federal search warrant was also executed at thesubject's residence. The subject admitted to using the Italian bank account as ameans to further forward the funds to his brother 's bank account in the MiddleEast.
Both subjects admitted to operating as an unlicensed money remitter. (Source:U.S. Customs Service)
SAR Assists in Identifying Money RemitterSending Money to Iraq
In March 2002, as a result of a lead provided from a SAR, an investigation wasinitiated into an individual doing business as an unlicensed money remitter. Thefunds were being wired to a bank account in Jordan.
In October 2002, U.S. Customs agents executed a search warrant on threeresidences and seized approximately $6,600, along with computers andnumerous documents. The subject admitted during an interview to sendingmoney to Iraq through his brother in Jordan. Moreover, the subject admittedthat he knew a portion of the funds was going to Saddam Hussein, as part of thecost of doing business in Iraq.
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In conjunction with the search warrants, agents interviewed clients of theunlicensed money remitter, who admitted that they knew the money was beingsent to Iraq via Jordan. (Source: U.S. Customs Service)
SARs Assist in Money Laundering InvestigationInvolving the Insurance Industry
Information generated from cooperating individuals during OperationsCornerstone, a major narcotics trafficking investigation in the Miami area,revealed narco-traffickers placed their drug proceeds into investments in theinsurance industry. Policies were identified in various Channel Island insurancecompanies containing the criminal proceeds. The investigation determined that anetwork of insurance brokers in the United States, soliciting clients in Colombiaand other South American countries, deposited drug proceeds into investmentaccounts on behalf of narcotics traffickers. Financial institutions submitted threeSARs to report structuring and suspicious activity by the insurance brokers.
To date, this investigation has resulted in the seizure of approximately$9.5 million dollars. The seizures are being made through 18 U.S.C. 981 and thefunds are being forfeited as proceeds of narcotics trafficking. (Source: U.S.Customs Service)
SARs Lead to Conviction of Former InvestmentFirm CEO
The former head of an investment firm was sentenced to nearly five years inprison as a result of a guilty plea to one felony count each for mail fraud and filinga false tax return, in a $146 million dollar scheme that targeted senior citizens.The subject pled guilty for his role in the investment scam that defrauded over1,800 investors over a four-year period. This individual operated a company thatclaimed to run a real estate investment program and promised investors a 12% to15% annual return. In reality, the company operated as a Ponzi-type scheme,paying early investors with funds obtained from later investments. The averageage of the investors was 67. The case was initiated from the filing of SARs by alocal financial institution detailing the subject's activity. The information wasprovided by the financial institution to local and federal law enforcementauthorities, which successfully investigated the allegations.
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Agencies participating in this investigation included the IRS-CriminalInvestigation, FBI and local law enforcement authorities. (Source: IRS-CriminalInvestigation)
SARs Assist in Conviction of Pharmacist
A business owner who ran a pharmaceutical business that defrauded drugmanufacturers was sentenced to nearly two years in prison, three months ofsupervised probation and ordered to make restitution of $513,369.40. Thesentence resulted from a guilty plea to one felony count each for conspiracy tocommit mail fraud and money laundering. The target pled guilty for his role inobtaining pharmaceuticals at a greatly reduced price based on false representationsto drug manufacturers and buying groups that the drugs would be only sold toinstitutional customers such as nursing home patients and adult foster homeclients. However, the target diverted the pharmaceuticals and resold them towholesalers, generating large and illicit profits. This case was initiated fromevaluation of informant information and supplemented by a review of SARs,which described large unexplained currency deposits.
Agencies participating in this investigation included IRS-Criminal Investigation,FBI, and the Food and Drug Administration. (Source: IRS-CriminalInvestigation)
SARs Identify Internal Fraud at Local Bank
On December 12, 2002, the Delaware State Police obtained a federal convictionfor bank fraud against a former bank employee. The subject was sentenced to twoyears federal incarceration and an additional five years federal probation. TheDelaware State Police received information from a local city bank that a currentbank employee was responsible for a bank fraud scheme at their bank. Thesubsequent investigation revealed that the subject was drafting cashiers checks inhis own name, and adjusting bank entries in an attempt to conceal the transactions.SARs were used to identify previous similar transactions by the subject, whichoccurred during employment at another bank. Also, BSA records assisted in theexpansion of the case investigation. Use of the SAR data and other BSA recordsof banking transactions were instrumental in the investigation to identify bankaccounts and the identification of expensive automobile and other cash purchases.(Source: Delaware State Police)
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Section 5 - Tips on SAR FormPreparation & Filing
Importance of Accurate and CompleteNarratives
Law enforcement and regulatory agencies, the primary users of SAR data,continue to report to FinCEN that SARs are filed with missing and incompletedata. Approximately 1% of SARs filed have neither an activity characterizationnor sufficient narrative to explain what activity is being reported. This conditionmost often occurs when filers check the activity characterization box marked"other" but fail to specify the suspicious activity on the line provided. Theproblem is compounded when filers enter the phrase "see attached" in thenarrative section of the form and attach items such as spreadsheets or computerprintouts as documentation. When forms are received at the IRS DetroitComputing Center (DCC), only information in an explicit, narrative format iskeypunched; thus, tables and other numeric data are not included in the narrative.SARs that do not specify the suspicious activity being reported or fail to providean explanation as to what led the institution to become suspicious are of minimalvalue to law enforcement or regulators.
Financial institutions should review and follow the instructions found in the"Suspicious Activity Information Explanation/Description" section of the SARform. Remember, the narrative section of the report is critical. The care withwhich it is written may make the difference in whether or not the describedconduct and possible criminal nature are clearly understood by law enforcementand regulators. Also, do not attach any supporting documents to the SAR butrather, provide a detailed description of the documentation in the narrative andretain the documentation for five years. Also, always select and mark theappropriate box(es) in the "summary characterization of suspicious activity"section.
Reporting Potential Terrorist-Related Activity ona SAR Form
General Instructions for Completing the SAR Form
FinCEN has received a number of calls from financial institutions requestingassistance in completing a SAR when the suspicious activity may be terrorist-related. The following guidance is offered: 1) report the information on the SARaccurately and completely; and 2) complete the narrative section by describing thesuspicious transaction as completely as possible and include the followinginformation, if applicable — any correspondent bank name/account information;names/locations of business entities; names of cities, countries and foreignfinancial institutions linked to the transaction, especially if funds transfer activityis involved; and account numbers and beneficiary names.
Specific Instructions for a Particular Industry
Financial institutions reporting potential terrorist-related activity on Form TD F90-22.47 are requested to check the "Other" box on Part III, Line 35(s) of theform and note the word "terrorism" in the space following the box. However, insome situations, the suspicious activity may also involve money laundering;therefore, the institution should also check Box 35(a).
Casinos and card clubs reporting potential terrorist-related activity on Form TD F90-22.49 (SARC) are requested to check the "Other" box on Part III, Line 32(n)and note the word "terrorism" in the space following the box. If the suspiciousactivity also involves money laundering, Box 32(h) or 32(j) should also bechecked.
MSBs reporting potential terrorist-related activity on Form TD F 90-22.56 shouldcheck Box 28 (c) (Terrorist financing) on Part II, Line 28. If the suspiciousactivity also involves money laundering, Box 28(a) should also be checked.
Regardless of which form is used, all filers should ensure that the narrativeincludes as much detail as possible regarding the potential terrorist-related andmoney laundering activities.
It is important to remember that a SAR should not be filed based on a person'sethnicity. In addition, a SAR should not be filed solely because a person appearsto have the same name as individuals identified by the media as terrorists.
Transactions to or from, or conducted by persons with possible affiliations withjurisdictions associated with terrorist activity should not be the only factor thatprompts the filing of a SAR. However, this information may be relevant andshould be considered in conjunction with other relevant information in decidingwhether a SAR is warranted, as set forth in 31 CFR 103.18 and the regulationsprescribed by the bank regulatory agencies, such as a lack of any apparent legal or
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business purpose to a transaction or series of transactions. Resources that shouldbe consulted about such jurisdictions include: the State Department's list of Statesponsors of terrorism20; the Treasury Department's OFAC's lists of foreignterrorists21; and FATF's list of non-cooperative countries and territories.22
Special SAR Form Completion Guidance forReporting Potential Informal Value TransferSystem Activity
Financial institutions should be alert to the use of IVTS in the movement of fundslinked to laundering of criminal proceeds or used to finance terrorism. The indicatorsof IVTS abuse for those purposes may be found in Section 2 — Trends and Analysis,of this publication. If any financial institution knows or suspects that an IVTS isbeing used in illegal funds transfer, a SAR should be filed.
Specific Instructions for a Particular Industry
Financial institutions reporting any known or suspected criminal or terrorist-relatedactivity conducted through IVTS on Form TD F 90-22.47 are requested to check the" Other" box in Part III, Line 35(s) of the form and note the abbreviation "IVTS" inthe space following the box. However, in some situations, the suspicious activitymay also involve money laundering; therefore, the institution should also check Box35(a). If the activity involves terrorism and an IVTS, check the "Other" box in PartIII, Line 35(s) and note the phrases, " Terrorism/IVTS" in the space following thebox. Also, the narrative should include an explanation why the financial institutionknows or believes an IVTS may be involved in the reported activity.
20 Pursuant to Section 6(j) of the Export Administration Act of 1979, the Departments of Stateand Commerce have designated the following countries as state sponsors of terrorism: Cuba,Iran, Iraq, Libya, North Korea, Sudan, and Syria. Further information about thesedesignations is available at www.state.gov. Additional information about countries in whichterrorists are highly active is available on that site in the State Department's Travel Warningsand Public Announcements page http://travel.state.gov/warnings_list.html.
21 OFAC designates and blocks the assets of specially designated global terrorists (SDGTs) -organizations and individuals engaged in international terrorism. For further information, seeOFAC's website at www.ustreas.gov/ofac.
22 FATF is an international organization, of which the United States is a member, established tocombat money laundering. Among other things, FATF evaluates the adequacy of countries'counter-moneylaundering systems, and designates those that have inadequate systems as non-cooperative countries and territories (NCCTs). Currently, FATF lists as NCCTs the following:Cook Islands, Egypt, Guatemala, Indonesia, Myanmar, Nauru, Nigeria, Philippines,St. Vincent and the Grenadines, and Ukraine.
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Financial institutions reporting any known or suspected criminal or terrorist-relatedactivity conducted through IVTS on Form TD F 90-22.56 (MSB SAR) are asked tocheck the "Other" box in Part II, Line 28(d) on the form and note the abbreviation" IVTS" in the space following the box. However, in some situations, the suspiciousactivity may also involve money laundering and/or terrorist financing; therefore, theinstitution should also check Box 28(a) and/or Box 28(c). Additionally, the narrativeshould include an explanation why the financial institution knows or believes anIVTS may be involved in the reported activity.
Casinos and card clubs reporting any known or suspected criminal or terrorist-relatedactivity conducted through IVTS on Form TD F 90-22.49 (SARC) are requested tocheck the "Other" box in Part III, Line 32(n) and write the abbreviation "IVTS" inthe space following the box. In some situations, the suspicious activity may alsoinvolve money laundering; therefore, the institution should also check Box 32(h). Ifthe activity involves terrorism and an IVTS, check the "Other" Box in Part III, Line32(n) and note the phrases, " Terrorism/IVTS" in the space following the box. Thenarrative should include an explanation why the financial institution knows or believesan IVTS may be involved in the reported activity.
Where to Send Completed SAR Forms
SARs (Treasury Form TD F 90-22.47) filed in paper format by either a depositoryinstitution, broker/dealer in securities, or others should be mailed to:
FinCENDetroit Computing CenterP.O. Box 33980Detroit, MI 48232-0980
SARs for Money Services Businesses (Treasury Form TD F 90-22.56) filed inpaper format should be mailed to:
FinCENDetroit Computing CenterATTN: SAR-MSBP.O. Box 33117Detroit, MI 48232-5980
SARs for casinos (Form TD F 90-22.49) filed in paper format should be mailedto:
FinCENDetroit Computing CenterATTN: SARC
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P.O. Box 32621Detroit, MI 48232-5980
SARs or SARCs filed by magnetic media/diskette format, should be mailed to:
IRS Detroit Computing CenterAttn: Tape Library985 Michigan Ave.Detroit, MI 48232
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Section 6 – SAR News Update
Expansion of SAR Requirements to New Industries
FinCEN is in the process of expanding SAR requirements to other financialservices industries and will be evaluating additional industries for future SARrequirements.
In September 2002, FinCEN issued a final rule that requires casinos and cardclubs to report suspicious transactions that involve or aggregate at least $5,000 infunds or other assets.23 The applicability date for suspicious transaction reportingby casinos and card clubs is March 25, 2003. All casinos and card clubs willreport suspicious transactions to FinCEN by submitting Treasury Form TD F 90-22.49, Suspicious Activity Report by Casinos (SARC). The reporting deadlinesand record retention requirements mirror those for other financial institutionsalready subject to SAR reporting requirements.
In October 2002, FinCEN issued a notice of proposed rulemaking to requireinsurance companies to report suspicious transactions that involve or aggregate atleast $5,000 in funds or other assets.24 The rule applies to businesses that offer lifeinsurance policies, annuity contracts, and other insurance products with similarfeatures used to store value and transfer that value to another person. The ruleapplies only to insurance companies rather than their agents or brokers. Thesuspicious transactions would be reported using a new form, the SuspiciousActivity Report by Insurance Companies (SAR-IC). Written comments on theproposed rule were due on or before December 16, 2002.
Also, in October 2002, a notice of proposed rulemaking was issued to requirecurrency dealers and exchangers to report suspicious transactions.25 The proposedrule amends 31 CFR 103.20(a)(2) by adding a fourth reporting category fortransactions suspected to involve the use of a money services business to facilitatecriminal activity. Currency dealers and exchangers will report suspicioustransactions by filing Treasury Form TD F 90-22.56, Suspicious Activity Reportby Money Services Business. Written comments were due on or before December16, 2002.
61
23 See 31 CFR Part 103.2124 See 31 CFR Part 103.1625 See 31 CFR Part 103.20
Proposed Revision of the SuspiciousActivity ReportIn November 2002, a notice and request for comments, issued jointly by FinCENand the federal regulatory agencies (OCC, OTS, FRB, FDIC, and NCUA), waspublished in the Federal Register. The notice proposes three minor revisions tothe SAR Form to add two new check boxes for terrorist financing and identitytheft in Part III, Box 35, suspicious activities, and to update the language in theSafe Harbor provision to that contained in the USA PATRIOT Act. The OCC isalso soliciting comments on all information collections contained in 12 CFR Part21. No new reporting requirements are being added. The deadline for writtencomments was on or before January 3, 2003.
Treasury Department Invokes USA PATRIOTAct/Section 311 AuthoritySection 311 (31 U.S.C. 5318A) authorizes the Treasury Department to designate aforeign jurisdiction, financial institution, class of transactions, or type of accountas being of "primary money laundering concern" and to impose one or more offive "special measures." In December 2002, this authority was invoked for thefirst time.26
On December 20, 2002, the Treasury Department, in consultation with other U.S.agencies, designated Ukraine as being of primary money laundering concern.Unless Ukraine demonstrates that it has taken proactive steps to address theconcerns giving rise to its designation, the Treasury Department may imposeconditions based on Special Measures 1— 4 of Section 311, which establishinformation gathering and record keeping requirements upon U.S. financialinstitutions dealing directly with Ukraine, or dealing with those having directdealings with Ukraine.
Also on December 20, 2002, the Treasury Department, in consultation with otherU.S. agencies, designated Nauru as being of primary money laundering concern.The Treasury Department may impose Special Measure 5, which will prohibitU.S. financial institutions from opening or maintaining correspondent accountswith Nauru-licensed financial institutions except the Bank of Nauru (which servesas the Central Bank for the country) to ensure the people of Nauru can continue tomeet their legitimate banking needs.
62
26 See Federal Register Notice, Vol. 67, No.248, December 26, 2002, p. 78859-78863.
The deadline to submit comments on certain aspects of the designation notice tothe Treasury Department was January 27, 2003.
FATF, through its NCCT process, works to generate the necessary political will tobring about national legislative and regulatory reforms to combat moneylaundering by the designated countries. As a result of their failure to put into placesufficient anti-money laundering frameworks, FATF called upon its members toimpose countermeasures with respect to Ukraine and Nauru.
63
Section 7 - Issues and GuidanceThis section of the SAR Activity Review discusses current issues raised with regardto the preparation and filing of SARs. This section is intended to identify SAR-related issues and then provide meaningful guidance to filers. In addition, thesection reflects the collective positions of the government agencies that requireorganizations to file SARs.
FinCEN Introduces the PATRIOT ActCommunication System
Pursuant to Section 362 of the USA PATRIOT Act, FinCEN was tasked withdeveloping a highly secure network to allow financial institutions to electronicallyfile certain BSA forms. FinCEN met this goal by making the PATRIOT ActCommunication System (PACS) available to the financial community on October1, 2002. Initially, only the forms filed by depository institutions, the CurrencyTransaction Report (Form 4789 or CTR) and the Suspicious Activity Report(Form TD F 90-22.47 or SAR) will be accepted through the electronicfiling process.
Financial institutions are not mandated to use PACS, but the system does providea third, cost effective option for filing CTRs and SARs. PACS allowsparticipating financial institutions to electronically file CTRs and SARs in ahighly secure fashion via the Internet, including both single forms and electronicbatches of forms. PACS enhances the security of the BSA form filing processthrough the use of digital signatures and secure Internet connectivity. PACSaccelerates the delivery of BSA information to federal and state law enforcementand it reduces the expense to the financial institution by eliminating the need formagnetic tapes and paper forms.
An institution incurs no cost to sign up or use PACS. However, financialinstitution personnel may access PACS only after they have applied for andreceived a digital certificate.
Visit the PACS website at http://www.pacs.treas.gov to find out more informationabout how PACS operates and how to become a PACS user.
65
66
Status of the USA PATRIOT Act Section314(a)/Information Requests
On November 4, 2002, FinCEN's Section 314(a) system began operation. Thesystem is designed to enable law enforcement to transmit the names of suspectedmoney launderers and terrorists to financial institutions through e-mail andfacsimile, and obtain responses of positive matches for certain account andtransaction information for the suspects within seven business days. Tentransmissions were made, arising from both money laundering and terroristfinancing investigations. Although, only the first request went through the entireprocess, each request resulted in the provision of useful information to lawenforcement. However, responding financial institutions raised a number ofquestions and issues. The concerns led FinCEN, after consultation with thefederal functional regulators and law enforcement officials, to place a moratoriumon the Section 314(a) process until the issues could be addressed. On February 17,2003, a public notice announced the resumption of the Section 314(a) system.
Court Agrees With FinCEN That SARs AndDocuments That Would Disclose Existence Of ASAR Are Absolutely Privileged From DiscoveryIn Civil Litigation
The previous issue of The SAR Activity Review discussed cases finding thatSection 5318(g)(2) of the BSA and its implementing regulations prohibit thedisclosure of a SAR in civil litigation. In a recent case, a magistrate judge inChicago determined that these regulations protect not only the SAR itself, but alsodocuments that would disclose that a SAR had been prepared and filed. Cotton v.Privatebank, ___ F.Supp.2d ___ (N.D. Ill. 2002), available at 2002 U.S. Dist.LEXIS 22155.
In Cotton, the principal of an entity that had established a trust to pay a structuredsettlement to a personal injury victim converted the funds. The victim sued thebank that had originally been the settlement fund trustee, as well as the broker-dealer at which the account was held during the period. (The converter pled guiltythree years prior to this decision). The bank sought discovery from the broker-
67
dealer to prove that the broker-dealer knowingly permitted improper withdrawalsfrom the account, including documents relating to an internal investigation, andany SAR and documents referring to the SAR. The broker-dealer (an affiliate of abank holding company and thus, subject to the SAR requirement) resisteddiscovery, citing the BSA, and notified FinCEN of the demand. In response to amotion to compel by the bank, FinCEN wrote to the magistrate-judge explainingthe legal and policy bases that should lead the court to deny the motion. Themagistrate-judge agreed, finding that the regulations issued by FinCEN and thefederal bank regulators establish an absolute privilege, even if the discovery isnecessary to raise an affirmative defense. He further found that the regulationswere valid. Finally, he found that the regulations require the withholding of anydocuments that discuss whether a SAR has been prepared or filed, as opposed tounderlying factual documents, which are not privileged.
Remember, an institution that finds itself in the position of receiving a request fordisclosure of a SAR as part of discovery in civil litigation should notify the courtof the prohibition from disclosure and, also, pursuant to the regulations of thefederal financial institution supervisory agencies, notify its federal supervisor, or ifit has no such supervisor, notify FinCEN that such a demand has been made.
69
Section 8 - Industry ForumIn each issue of the SAR Activity Review, representatives from the financialservices industry offer insights into some aspect of compliance management orfraud prevention that presents their view of how they implement the BSA withintheir institution. Although the Industry Forum Section provides an opportunity forthe industry to share its views, the information provided in it may not representthe official position of the regulators. In this issue, the American BankersAssociation (ABA) offers their "Check Fraud Loss Report" from the second quarterof 2002. For more information, please contact John Byrne, ABA Senior Counseland Compliance Manager, at [email protected].
TOP FIVE LOSS CATEGORIES (by Number ofAccounts)
1. Forged maker's signature (2)
2. Counterfeit (1)
3. NSFs (4)
4. Return losses excluding closed accounts, NSFs, stop payments, refer to maker,government reclamations, and uncollectable funds (other return loss reasons)(3)
5. Closed accounts (5)
*Last quarter 's rank in parentheses
HIGHLIGHTS:
• In the second quarter, check-related losses averaged $1.02 per transactionaccount. This is an 11 percent decrease from the previous quarter and ayear ago (both at $1.14 per transaction account). Losses decreased 22.5percent in the West region, 7.8 percent in the Southwest region, 4.5 percentin Central region, and 0.3 percent in the Southeast region. There was a 5.6percent increase in losses in the Northeast region.
70
• The West had the highest losses per transaction account (at $1.19),followed by the Southwest (at $1.02), Southeast (at $0.99), Central (at$0.99), and the Northeast (at $0.80).
• Overall, forged makers signature became the number one loss category,followed by counterfeits, NSFs, other return loss reasons, and closedaccounts. By region, the top loss categories were forged makers signaturein the Northeast, Southeast, and Southwest regions, and counterfeit in theCentral and West regions.
• Three check fraud loss categories showed an increase in losses this quarter.Government reclamations increased by 26.4 percent, followed by kiting(25.4% increase) and forged maker's signature (10.6% increase). Otherreturn loss reasons decreased the most, down 30.1 percent, followed bystop payments (down 25.9%), NSFs (down 20.7%), and closed accounts(down 18.1%).
• Compared to the same period last year, losses decreased in mostcategories. Only two categories showed an increase from the previousyear, closed accounts (increased by 3.5%) and forged makers' signature(increased by 2.3%). By contrast, kiting decreased 65.5 percent and otherreturn loss reasons decreased 53.7 percent.
• Nationally, losses per case averaged $1,405, lower than $1,503 in theprevious quarter, but higher than the $1,169 a year ago. Losses per caseaveraged $2,822 in the Northeast, $1,444 in the Central region, $1,271 inthe West, $1,183 in the Southeast, and $1,150 in the Southwest.
• New account losses decreased in the second quarter to $0.26 pertransaction account or $7.32 per new account ($0.27 and $8.15,respectively, in the first quarter). By region, new account losses increasedin the Northeast and Southeast, but decreased in the Central, Southwestand West regions. New account losses were 25.4 percent of total losses insecond quarter, higher than the 23.6 percent in the first quarter.
• Losses from identity fraud increased to $0.05 per transaction account inthe second quarter, compared to $0.03 in the first quarter.
Appendix 1Characterization of Suspicious Activity by
States and Territories by Year
Appendix 1
72
27136
119
39
00001001
Alabama1996199719981999200020012002TOTALAlaska1996199719981999200020012002TOTAL
Wire
Tra
n sfe
r Fra
ud
Oth
er
Violations by State by Year For the Period April 1, 1996 through October 31, 2002
BSA/
Stru
ctur
ing /
Mon
ey L
aund
erin
g
State/Territory Violation
B rib
ery/
Gra
tui ty
Chec
k Fra
ud
Chec
k Ki t i
ng
Com
mer
c ia l
Lo a
n Fr
a ud
Com
pute
r Int
rusio
n
Coun
terfe
i t Ch
eck
Coun
terfe
i t In
st rum
ent (
Oth
er)
Cred
i t Ca
rd F
raud
De f
a lca
tion /
Embe
zzle
men
t
F alse
Sta
teme
nt
Misu
se o
f Po s
it ion
or S
el f D
e al in
gM
ortg
a ge
Loa n
Fra
u d
Mys
terio
us D
isapp
eara
n ce
77899391
179315267
1,111
393695
119285233272
1,079
01102149
00000000
466871
121162267245980
9668
16112278
38444663929585
463
5266
1118
39
71414
915201291
01002003
0000244
10
00000202
8171810182124
116
01004308
1951243247
10584
362
2221259
23
1029232
19
00000000
1112234
14
00124119
9201926254628
173
0014572
19
11324
111537
10102015
23524761778868
416
273468
1343
8171410372723
136
002243
1021
9202127454632
200
316011
1123
Cons
u mer
Loa
n F r
aud
Cou n
terfe
it Cr
e di t/
Deb
i t Ca
rd
Deb
it Ca
rd F
raud
27384970
114195153646
44
1012242646
126
25534833333229
253
3432523
22
221443
1834
0021365
17
73
00000000
12241
511
239
81418
00016029
5384
136138479472928
2,290
American Samoa
1996199719981999200020012002TOTALArizona1996199719981999200020012002TOTAL
00000011
9101030517255
237
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA /
S tru
ctu r
i ng /
Mo n
ey L
aun d
eri n
gBr
iber
y/G
ratu
it y
Chec
k F r
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n F r
aud
Com
put e
r In t
rusi o
n
Coun
t erf e
it Ch
eck
Coun
t erfe
it In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
E mbe
zzl e
men
t
F al s
e St
a tem
ent
Misu
se o
f Pos
i t io n
or S
e lf D
eali n
gM
ortg
age
L oan
Fra
ud
Mys
t eri o
us D
i sap p
eara
nce
00002024
361598955
1,5261,7262,3174,531
12,014
00000011
00000336
00001113
187290317268435643647
2,787
00000000
71575251
10282
104519
00000000
34286
121247
00000000
00000325
00000000
87592030224460
322
00010001
38141179206213245162
1,184
00000000
413113748
50
00000000
2121,232
559191798432
2,8066,230
00000000
7272322433923
184
3070221
15
8216210283
130191125875
00000000
73552330598061
381
00001012
13283245386642
264
Con
sum
er L
oan
Frau
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
i t C a
rd F
rau d
00001001
86
137
1628
987
00000000
2586
1317
163214
State/Territory Violation
74
Arkansas1996199719981999200020012002TOTALCalifornia1996199719981999200020012002TOTAL
07386
161050
6821,025
759599638
1,0741,3146,091
Wire
Tra
nsf e
r Fra
ud
Oth
er
B SA/
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
rat u
i ty
Che
ck F
raud
Che
ck K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusio
n
Coun
terf e
i t C h
eck
Coun
terf e
i t In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
Embe
zzl e
men
t
F al se
St a
t em
ent
Mi s
u se
o f P
o sit i
on o
r Sel
f Dea
li ng
Mor
t gag
e Lo
an F
rau d
Mys
teri o
us D
isapp
eara
n ce
44958696
164199238922
5,2419,202
13,49816,51332,13939,06739,110
154,770
0210751
16
12131312273569
181
224742
12310398
147582
2,4382,9603,1143,0374,0345,3134,719
25,615
19374063597655
349
278480479347482812844
3,722
6281521405440
204
58115104170156141109853
00002237
0000
10512586
3111018242912
107
281488402570782
1,390744
4,657
477
18482229
135
7671,2371,331
9231,5161,9791,9509,703
00000011
17242234
12219746
462
1123136
17
1325293959
10152
318
45
171712162596
78203274413637788325
2,718
0212351
14
258597
184239190175995
23414234384742
267
7671,2231,2761,0261,0491,064
7947,199
6301513183122
135
512564440639813616580
4,164
2117
919283529
158
112185171169219246229
1,331
Con
sum
er L
oan
F rau
d
Coun
t erf e
i t C r
e dit /
Deb
i t Ca
rd
De b
it Ca
rd F
raud
233445
11588
127205637
536906
1,2451,0171,1102,4682,6949,976
26242720436437
241
61166215122135153103955
6518
10131154
356561
102114202223802
State/Territory Violation
75
Colorado1996199719981999200020012002TOTALConnecticut1996199719981999200020012002TOTAL
54
1918325745
180
4121620202513
110
Wir
e Tr
ansf e
r Fra
ud
Oth
er
B SA /
Stru
ctur
ing /
Mo n
ey L
aund
erin
gB r
iber
y/G
ratu
it y
Che
ck F
raud
Che
c k K
i ting
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusio
n
Cou
nter
f ei t
Che
ck
Coun
terf e
it In
stru m
e nt (
Oth
er)
Cre
dit C
a rd
Frau
d
Def
a lc a
ti on /
E mbe
zzl e
men
t
F als
e St
atem
ent
Misu
se o
f Pos
i tion
or S
elf D
ealin
gM
ortg
age
Loan
Fra
u d
Mys
terio
u s D
i sapp
e ara
nce
275420602832
1,0881,8174,6699,703
149373480583868874
1,2284,555
02
100259
28
00010214
156283299245310469351
2,113
60115114
77164152212894
347164
108142169113701
30605540432848
304
2779
17211982
567
1094
69110
00002
152
19
00000134
15171518215350
189
9213111
91515
111
58568283
181219126805
122745506663
108371
544
12284
39
0110363
14
08427
111850
1097
1037
37
204099
110444767
427
2232013234532
158
57
101913221086
005274
1331
4552897098
14283
579
26604635344264
307
22192426447366
274
6153427182248
170
11213423345053
226
111315
812
92391
Con
sum
er L
oan
F rau
d
Cou
n ter
f ei t
Cre
dit /D
ebi t
Card
Deb
i t C
ard
Frau
d
52163146114143346394
1,358
567974
17985
8352,0153,323
24334334416240
277
15152414322531
156
17
403
102146
128
137
129
142369
State/Territory Violation
76
0136453
22
510
716
141154
06
2254
1263522
265
146368
1139
Delaware1996199719981999200020012002TotalDistrict ofColumbia1996199719981999200020012002TOTAL
4121115395257
190
00103026
57210317211347669736
2,547
82023195178
110309
2100
14145
73235
1003
1146
25
Wire
Tra
n sf e
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mo n
ey L
aund
erin
g
B rib
ery/
Gra
tui t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r In t
rusi
on
Cou n
t erfe
i t C
hec k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cred
it Ca
rd F
raud
De f
alca
t i on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
124540
170128123251769
536680
146242313311
1,211
00010113
01000203
28132229253427651793
2,513
355969677079
102481
12801823
1,080933
1,0973,243
121594
116
1067
0035826
24
0131413
13
00001438
00000101
11
113444
132280503
6263
1172
37
30136205290496420476
2,053
10212135474340
217
118
26
2214
972
2131323
15
153811800795
1,1891,6752,5287,951
052414
2339
1355
10716
9146
2431834
25
5131223242418
119
14143915393429
184
511101014211990
3765
1118
858
810108999
63
2224
1167
34
Con s
umer
Loa
n Fr
a ud
Coun
terf e
i t C
redi
t/Deb
i t Ca
rd
Deb
i t Ca
rd F
raud
State/Territory Violation
77
00100001
2,3024,1494,8735,0775,8817,4878,808
38,577
FederatedStates ofMicronesia
1996199719981999200020012002TOTALFlorida1996199719981999200020012002Total
00000000
0388
84131
29263
02101015
200368399517804842
1,4044,534
00000000
4458
110358420416413
1,819
Wir
e T r
ansf
er F
raud
Oth
er
BSA/
Stru
ctur
ing/
Mon
ey L
aund
eri n
gB r
iber
y/G
ratu
i t y
Che
ck F
raud
Che
c k K
i ting
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r Int
rusi
on
Co u
nter
f eit
Che c
k
Coun
t erf
eit I
n stru
men
t (O
the r
)
Cre
dit C
a rd
Frau
d
Def
alca
t i on/
Embe
zzl e
men
t
False
St a
t em
ent
Mi su
se o
f Pos
i tion
or S
elf D
eal i n
gM
ortg
age
Loan
Fra
u d
Mys
t eri
o us D
i sapp
e ara
nce
00000000
885
1011101264
01101003
672925573677991
1,3511,8677,056
01000012
158235130173278277395
1,646
00000000
19251633657170
299
00000011
00002
161230
00000011
511266893
231117141827
00001001
34148190458511497798
2,636
00001001
8181915248943
216
00000011
1155
142245158222455
1,288
00000000
14181520746149
251
12010004
105198171210306274222
1,486
00000112
69112
64102186155118806
00202116
39596482
1227097
533
Cons
umer
Loa
n F r
aud
Cou
n ter
f ei t
C red
i t/D
ebi t
C ard
Deb
it C a
rd F
raud
00000022
67886982
1169277
591
00000000
1726462656
106140417
State/Territory Violation
78
28779491966393
542
03120107
Georgia1996199719981999200020012002TOTALGuam1996199719981999200020012002TOTAL
1337247096
103187530
00000000
Wir
e Tra
nsfe
r Fra
ud
Oth
er
B SA /
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
ratu
it y
Chec
k Fra
ud
C hec
k Ki t i
ng
Com
mer
cial
Loa
n Fr
a ud
C om
put e
r Int
rusi o
n
C oun
t erf e
it C
heck
Co u
nter
fei t
Inst r
umen
t (O
t her
)
C red
i t Ca
rd F
raud
Def
alca
t ion /
E mb e
zzle
men
t
F al se
Sta
t em
ent
Misu
se o
f Pos
i tion
or S
elf D
eal in
gM
ort g
age L
o an
Frau
d
Mys
t erio
us D
i sap
pea r
ance
207473648926
1,2461,3631,8486,711
5192947394263
244
1320585
24
00041005
68262259286574834870
3,153
514
8599
1565
36100
6786
104156195744
0134730
18
7183523262723
159
10001305
00000
182
20
00000000
2030526068
10483
417
03000216
15123141241383537394
1,834
00000426
0534
20313093
00000000
289
113
121560
00001102
74193119164111230265
1,156
01000113
28
1311362428
122
01411000
16
6096
130115145143135824
16246
109
38
25536286583852
374
2014323
15
17466057596549
353
132
12677
38
Cons
umer
Loa
n F r
aud
C oun
t erf e
i t C
red i
t /Deb
it Ca
rd
Deb
i t C a
rd F
raud
66122162147336516652
2,001
615111710111686
511
813334063
173
11100205
State/Territory Violation
79
Hawaii1996199719981999200020012002TOTALIdaho1996199719981999200020012002TOTAL
1000458
18
3132633
21
Wire
Tra
nsf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
gB r
i ber
y /G
ratu
i ty
Ch e
ck F
raud
Che
ck K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it C a
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
224348369382579799634
3,335
11394275
274183143767
00105017
00000101
44403937314338
272
17331934355443
235
611
44
1317
863
7181221242418
124
2101321
10
1232062
16
00000235
00001203
0805647
30
14344
111441
106
2114153024
120
417
176
112268
0134204
14
00100001
10011126
00001023
21616
713
76
67
1343224
19
11301219
02001407
24311719251810
144
7281516193715
137
6540305
23
27348
171556
4338813
30
176
11314
33
Con
sum
er L
oan
Fra u
d
Coun
t erf e
i t C r
edit /
Deb
i t C
a rd
Deb
it Ca
rd F
raud
628291694959
251663
3161020133528
125
553
10605
34
1521641
20
1221107
14
01011148
State/Territory Violation
80
Illinois1996199719981999200020012002TOTALIndiana1996199719981999200020012002TOTAL
35465780
176183108685
04
106
313236
119
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA /
S tru
ctu r
i ng /
Mo n
ey L
aun d
eri n
gBr
iber
y/G
ratu
it y
Chec
k F r
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n F r
aud
Com
put e
r In t
rusi o
n
Coun
t erf e
it Ch
eck
Coun
t erfe
it In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
E mbe
zzl e
men
t
F al s
e St
a tem
ent
Misu
se o
f Pos
i t io n
or S
e lf D
eali n
gM
ortg
age
L oan
Fra
ud
Mys
t eri o
us D
i sap p
eara
nce
279670720
1,1091,6352,0583,704
10,175
148277379462551687
1,0563,560
699
13776
57
2002355
17
290809774
1,026941
1,1951,5696,604
5898
113198206282293
1,248
102242213206233289267
1,552
35507168828099
485
326155659394
120520
8121614272126
124
00006
3760
103
00000516
21615196
1607580
544
12203933313666
237
41121164339492442480
2,079
41826
103107129100487
019
64
2028
986
12100228
8165
2181
168162461
5014069
25
1498
103140104114208781
529
718212711
118
4271626344444
195
1757
115
1046
96244211277380400307
1,915
5698
104104115120
74671
28859155
106126117608
19261924433949
219
397586
112110144211777
10173434505830
233
Con
sum
er L
oan
Frau
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
i t C a
rd F
rau d
115287295268466542889
2,862
62102145141135163204952
62118123157130
90100780
26413472748356
386
621173542
115306542
26327
263985
State/Territory Violation
81
Iowa1996199719981999200020012002TOTALKansas1996199719981999200020012002TOTAL
1203776
26
1447
14333598
Wire
Tra
nsf e
r Fra
ud
Oth
er
B SA/
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
rat u
i ty
Che
ck F
raud
Che
ck K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusio
n
Coun
terf e
i t C h
eck
Coun
terf e
i t In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
Embe
zzl e
men
t
F al se
St a
t em
ent
Mi s
u se
o f P
o sit i
on o
r Sel
f Dea
li ng
Mor
t gag
e Lo
an F
rau d
Mys
teri o
us D
isapp
eara
n ce
319691
169218245270
1,120
5073
123159153259439
1,256
00100113
01001248
2035334349
10578
363
254451
10074
10974
477
60595545416255
377
10202854316684
293
3231121322738
155
10182119434132
184
0000174
12
0000365
14
11410
95
173591
713
91012211991
364
15184228
116
294
26164131
129
01220308
01101104
01110003
1124453
20
2202615144028
145
1177
157
242091
112
47733
37
0014299
25
14252927334927
204
17314455395349
288
10291821233658
195
10211518273844
173
89
1410113222
106
2111120202739
130
Con
sum
er L
oan
F rau
d
Coun
t erf e
i t C r
e dit /
Deb
i t Ca
rd
De b
it Ca
rd F
raud
2971496077
228193707
5348408779
121341769
9101017132716
102
10212736375239
222
374758
1246
0372
119
2658
State/Territory Violation
82
Kentucky1996199719981999200020012002TOTALLouisiana1996199719981999200020012002TOTAL
21174
179
41
10053
1110
948
Wire
Tra
n sf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gB r
i ber
y /G
ratu
i ty
Chec
k Fr
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it Ca
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
76104144345362571687
2,289
154157193297
1,1631,3591,5094,832
1100224
10
112
00018
22
4378656795
130224702
64105
99180228301257
1,234
1127584650
135109436
5976809499
154149711
7201426182940
154
825
923223019
136
0000096
15
0000182
11
6239
26262423
137
6261717485641
211
65
1436296359
212
1313777192
10462
432
00000145
00101237
2110352
14
0323456
23
467
195
3278
151
8342128285334
206
54355
221660
4463258
32
19595955547757
380
41807673
116106
78570
69
1539253824
156
11342345402320
196
8271926364337
196
11383643634028
259
Con
sum
er L
oan
Fra u
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
it Ca
rd F
raud
286358
101140144253787
56518599
109121242763
27261628204040
197
26332928554720
238
33924
142560
373
126
112870
State/Territory Violation
83
Maine1996199719981999200020012002TotalMarshallIslands1996199719981999200020012002TOTAL
00210003
00000000
1522
919124253
172
00000000
0221311
10
00000000
Wire
Tra
n sfe
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mon
ey L
aund
erin
gB r
iber
y/G
ratu
i t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r In t
rusi
on
Cou
nter
fei t
Che
c k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cre
d it C
a rd
F rau
d
De f
alca
ti on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
28576366
108100164586
00000011
00100203
00000000
11395329346066
292
00000011
31402030334527
226
00000000
3516641
26
00000000
00000101
00000000
87333
111348
00000000
549
1013142580
00000000
01010507
00000000
35495
124
42
00000000
144607
1133
00000000
328
169
111160
00020114
5944948
43
00000000
15787
126
46
00010001
Con s
umer
Loa
n F r
a ud
Cou
n ter
f ei t
Cre
dit/D
ebi t
Card
Deb
i t C
ard
F rau
d
45
11141311
664
00000000
2339182
28
00000000
State/Territory Violation
84
Maryland1996199719981999200020012002TOTALMassachusetts1996199719981999200020012002TOTAL
154748
156290245322
1,123
62211
9252724
124
Wire
Tra
n sfe
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mon
ey L
aund
erin
gB r
iber
y/G
ratu
i t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r In t
rusi
on
Cou
nter
fei t
Che
c k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cre
d it C
a rd
F rau
d
De f
alca
ti on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
235386600813893982
1,3025,211
384760971
1,6811,7941,4222,4109,422
01000269
120202
1421
121172143142291301345
1,515
34223364316367579721
2,604
37445138636470
367
22656769436140
367
915
9496
77129
5121719132319
108
00000347
0000547
16
10111813202224
118
11161115163820
127
112855
110193143203743
26416789
144118174659
00003429
0017364
21
2271234
21
0337255
25
10445739263325
234
32626332131
9149
17
105
17181977
464
1421151781
5590
10786
138116
87679
3698757667
103137592
19453718493633
237
15343130618653
310
10172114274616
151
7392028273742
200
Con s
umer
Loa
n F r
a ud
Cou
n ter
f ei t
Cre
dit/D
ebi t
Card
Deb
i t C
ard
F rau
d
40799492
160268488
1,221
8592
153105193276491
1,395
23242948545545
278
8192224383359
203
65648
251569
3132022332940
160
State/Territory Violation
85
Michigan1996199719981999200020012002TOTALMinnesota1996199719981999200020012002TOTAL
59
1247
412440293
1,223
280
1211212579
Wire
Tra
n sfe
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mon
ey L
aund
erin
gB r
iber
y/G
ratu
i t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r In t
rusi
on
Cou
nter
fei t
Che
c k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cre
d it C
a rd
F rau
d
De f
alca
ti on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
206306274668
1,0331,9502,1496,586
5621,4551,1811,1791,5881,4212,3169,702
3470235
24
1021866
24
195361365581773843857
3,975
130326560719578709378
3,400
119254225144172188230
1,332
297687
137116182108735
10443620504139
240
2252519412143
176
00001
101930
00000
112
13
33484271846563
406
56
1527333324
143
41174308412447423260
2,065
93171
119156209103648
2223
1096
34
01212309
84479
121458
0346823
26
84883
183459978
544
36
1716263931
138
10412344587437
287
6222260547512
251
108236254244283232251
1,608
3246689692
127103564
256786
108199185159829
153831304566
119344
28719296
1117260
530
22353041758935
327
Con s
umer
Loa
n F r
a ud
Cou
n ter
f ei t
Cre
dit/D
ebi t
Card
Deb
i t C
ard
F rau
d
130177183383345306456
1,980
44205130
78100311504
1,372
5591
10092
1119280
621
22412928605326
259
3959
222139
108
2953
11253590
State/Territory Violation
86
BSA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
g
Mys
teri o
u s D
i sapp
eara
nce
Mississippi1996199719981999200020012002TOTALMissouri1996199719981999200020012002TOTAL
1303558
25
741463893
178149552
Wire
Tra
nsf e
r Fra
u d
Oth
er
B ri b
ery /
Gra
tui ty
Ch e
ck F
raud
Che
ck K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it C a
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
23555669
277337353833
130178214237403651894
2,707
01111127
0001424
12
17453542586663
326
107264324273250424319
1,961
31535135415537
303
3457438284
140116556
386
1518311899
13434235625451
300
00000516
0000183
12
5649
17221780
820151650
16577
351
447
1411321789
113950
11698
181109604
00101013
08775
102
39
00013127
4332856
31
013
759
162
52
18613435384627
259
1133312
14
2161415134020
120
25422055485045
285
4484
11712914913778
738
516
537373810
148
28494543
103125103496
18201139393231
190
20333652616136
299
Con
sum
er L
oan
Fra u
d
Coun
t erf e
i t C r
edit /
Deb
i t C
a rd
Deb
it Ca
rd F
raud
10232829647459
287
4394
147135295377345
1,436
6108
1312161883
3563666280
10167
474
2012335
16
211
58
104938
123
State/Territory Violation
87
3536578
37
311
91416101679
Montana1996199719981999200020012002TOTALNebraska1996199719981999200020012002TOTAL
21102028
03444
106
31
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA/
Stru
ctur
ing/
Mon
ey L
aund
eri n
gB r
iber
y/G
ratu
i t y
Chec
k Fr
a ud
Chec
k K
i ting
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r Int
rusi o
n
Coun
t erf e
it Ch
e ck
Coun
t erf e
it In
strum
ent (
Oth
e r)
C red
i t C a
rd F
rau d
Def
alca
t i on/
Embe
zzl e
men
t
Fals
e St
atem
ent
Mi su
se o
f Pos
i tion
or S
elf D
eal i n
gM
ortg
age
Loan
Fra
u d
Mys
t erio
us D
i sap
pear
ance
22394872
124120
84509
5352
114147294375569
1,604
00000000
2002117
13
288
22233417
114
28405073
110117109527
813
68
20241796
6182225557444
244
1431136
19
112
91814192699
00000202
00000
111,0441,055
1634368
31
38
119
16171579
1459
21211778
477
11123048
119
01000001
0150052
13
00101338
2001056
14
02010306
0182321
97
536614
03200106
032153
3246
413111211211789
12321825423323
185
2543597
35
52423191920
105215
75412
134
36
41488
252126
106
Cons
umer
Loa
n F r
aud
Coun
terf e
i t C r
edi t/
Deb
i t C
ard
Deb
it C a
rd F
raud
10151523173840
158
1938402949
102275552
0210315
12
043335
872889
State/Territory Violation
88
455
1326281798
23
202512
94
75
273466
1038
1110461
14
Nevada1996199719981999200020012002TOTALNewHampshire1996199719981999200020012002TOTAL
0215972
26
000
213
373
64
18668097
112225209807
315172011
391312769
2712
114461222
134
0032341
13
Wir
e Tra
nsf e
r Fra
ud
Oth
er
B SA /
S tru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
ratu
it y
Chec
k Fra
ud
C hec
k Ki t i
ng
Com
mer
cial
Loa
n Fr
a ud
C om
put e
r Int
rusi o
n
C oun
t erf e
it C
hec k
Co u
nter
fei t
Inst r
umen
t (O
t her
)
C red
i t Ca
rd F
raud
Def
alca
t ion /
E mbe
zzle
men
t
F al se
Sta
tem
ent
Misu
se o
f Pos
i tion
or S
elf D
eal in
gM
ort g
age L
o an
Frau
d
Mys
t erio
us D
i sap
pea r
ance
322619718867
1,2521,5641,5256,867
436191
105128108197733
00201115
0003351
12
93183223275347416309
1,846
17236191250
97153117
1,061
51675450
185428453
1,288
5692537591715
227
256
1612
64
51
2231121
12
00000617
00000202
18417711446536
1852
2,198
01242
103
22
75292
157194173120795
15
1428
141559
1438692
33
02100115
11112747
231217224768
3165140146135548336
1,473
154
1029181279
0311367
21
38636866945752
438
419
715
6111577
31272725221713
162
1131639
34
8131220179
21100
0714496
31
Cons
umer
Loa
n F r
aud
C oun
t erf e
i t C
red i
t /Deb
it Ca
rd
Deb
i t C a
rd F
raud
State/Territory Violation
89
New Jersey1996199719981999200020012002TOTALNew Mexico1996199719981999200020012002TOTAL
1391
226531104
8875
1,128
300223
1020
Wir
e Tra
n sfe
r Fra
u d
Oth
er
B SA/
Stru
ctur
ing/
Mon
ey L
aun d
eri n
gB r
i ber
y/G
rat u
i t y
Chec
k F r
aud
Chec
k K
i t in g
C om
me r
c ial
Loa
n F r
aud
Com
pute
r Int
rusio
n
Co u
nter
fei t
C hec
k
Cou
nter
feit
Inst
rum
ent (
Ot h
er)
Cre
dit C
ard
Frau
d
Def
a lca
ti on/
Embe
zzl e
men
t
F al se
Sta
t em
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mo r
t ga g
e Loa
n Fr
a ud
Mys
teri o
us D
isap p
eara
n ce
343593
1,0581,8372,3882,6413,949
12,809
7572
128145172235461
1,288
111201
1016
00101147
174284317352669999836
3,631
35664545536298
404
204968738892
175565
9122720153242
157
49
2518142144
135
121
1315
1033
00002125
00001012
9142240389979
301
4005
12166
43
36123134147197194334
1,165
1099
1316172599
1323
2659
296
00102003
13998
5515
100
01020137
3443566689386
395
25225
115
32
512101022
20931
299
2232152
17
71117144140225218193
1,108
29233019243622
183
24513186535470
369
73469
129
50
18382234424146
241
115
111113139
73
Cons
umer
Loa
n Fr
a ud
Cou
nter
f ei t
Cred
it /D
ebit
Car
d
Deb
it Ca
rd F
raud
149232275158336557600
2,307
25331438436784
304
41427656738273
443
1413219
112210
100
711
91526
103108279
023124
2234
State/Territory Violation
90
New York1996199719981999200020012002TOTALNorth Carolina1996199719981999200020012002TOTAL
22804168
170215205801
3292723
143116126467
Wire
Tra
nsf e
r Fra
ud
Oth
er
B SA/
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
rat u
i ty
Che
ck F
raud
Che
ck K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusio
n
Coun
terf e
i t C h
eck
Coun
terf e
i t In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
Embe
zzl e
men
t
F al se
St a
t em
ent
Mi s
u se
o f P
o sit i
on o
r Sel
f Dea
li ng
Mor
t gag
e Lo
an F
rau d
Mys
teri o
us D
isapp
eara
n ce
2,4485,6677,971
11,25113,75115,91018,00975,007
317610831898
1,216954
1,1495,975
17231317214743
181
141022
1323
5781,2671,4741,8371,8922,7612,031
11,840
113274273358404379373
2,174
201323365306288247226
1,956
69153146184204157274
1,187
3911510615010593
121729
3201831262727
152
00005
301146
0000074
11
336170
109153292161879
8584986
124123119567
199631966926950
1,2211,2426,135
22135173252262148205
1,197
594
64417340
236
0852043
22
2472707594
104106545
34688
107
46
23173124271216257365
1,429
7879
176167
566316
635
17322231434349
237
01331317
2512
119
174377301327288280338
2,085
5799
123134139141122815
53211220164137171173
1,129
16525256648255
377
41108
91104
8083
102609
23655295837257
447
Con
sum
er L
oan
F rau
d
Coun
t erf e
i t C r
e dit /
Deb
i t Ca
rd
De b
it Ca
rd F
raud
601946
1,2971,1561,1921,8082,2459,245
75136188212252457449
1,769
61114118101
919294
671
32769660784744
433
23128136150182223356
1,198
5131223252541
144
State/Territory Violation
91
North Dakota1996199719981999200020012002TOTALNorthernMariana Islands1996199719981999200020012002TOTAL
00000101
00000000
313
925134649
158
4142213
17
00023106
00000000
Wire
Tra
nsf e
r Fra
ud
Oth
er
B SA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
gBr
i ber
y/G
ratu
i t y
C hec
k Fra
ud
C hec
k Kit i
ng
C om
mer
cial
Loa
n Fr
a ud
C om
p ute
r Int
rusi o
n
C oun
t erf e
it C
h eck
C oun
terf e
i t In
st rum
e nt (
Oth
e r)
C red
i t C a
rd F
rau d
Def
alc a
ti on/
E mb e
zzl e
men
t
F alse
St a
t em
ent
Mi su
se o
f Pos
i t io n
or S
elf D
eal i n
gM
ort g
age L
oan
Frau
d
Mys
t erio
u s D
i sapp
eara
nce
5148147
45744449
512
1413
18513357
177
01100002
00000000
6231616121721
111
2144024
17
29
1511222521
105
1224010
10
39
15121789
73
00000000
00000404
00000000
4347422
26
00000000
0013
1144
23
00000000
00102306
00000000
1322
644250
164
00010001
02011015
00011002
1675495
37
11112107
34
119749
47
11010025
2532
10106
38
00110204
Cons
umer
Loa
n Fr
aud
C oun
t erf e
it C
red i
t /Deb
it C a
rd
Deb
i t C a
rd F
rau d
1114342
16
00020002
00112239
00012003
State/Territory Violation
92
Ohio1996199719981999200020012002TOTALOklahoma1996199719981999200020012002TOTAL
56
215393
417171766
00266
151443
Wire
Tra
nsf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
gB r
i ber
y /G
ratu
i ty
Ch e
ck F
raud
Che
ck K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it C a
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
179379754639969
1,3932,0155,728
124211174247293329411
1,789
112
1016
1031
0300126
12
122318329399551594852
3,165
235981
138140125119685
79232213262453342288
1,869
73635461655950
425
10171829598692
311
12283634312247
210
00003
168
27
00001528
216687
106106124202712
2117
3316121899
2059
132212297274366
1,360
6161438454247
208
0874
10215778
356
11001003
5837
10152068
4444625
29
13199120151259446168
1,356
08
1311282911
100
6202522322237
164
054
11862
36
102201217217253219171
1,380
22414872857554
397
1625416969
11567
402
8211440323233
180
28517399
107124
86568
9151718391528
141
Con
sum
er L
oan
Fra u
d
Coun
t erf e
i t C r
edit /
Deb
i t C
a rd
Deb
it Ca
rd F
raud
85185209210254435483
1,861
31546584
129140258761
31778998
118123131667
9191416313138
158
367
162057
119228
12
1663
142971
State/Territory Violation
93
Oregon1996199719981999200020012002TOTALOverseas1996199719981999200020012002TOTAL
3869
18182082
00000000
Wir
e Tra
nsf e
r Fra
u d
Oth
er
B SA /
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gBr
i ber
y/G
rat u
it y
C hec
k Fra
u d
Che c
k Ki ti
ng
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r In t
rusi o
n
Cou
nter
fei t
C hec
k
C oun
t erf e
it In
stru
men
t (O
t her
)
Cre
dit C
ard
Fra u
d
Def
alca
t ion/
E mbe
zzle
men
t
False
St a
t em
e nt
Mi s
use
of P
osit i
on o
r Sel
f Dea
l ing
Mor
t gag
e Lo a
n Fr
aud
Mys
t eri o
us D
i sapp
eara
nce
178360451615
1,5421,354
7155,215
934
12741
58
10011418
00000022
133298281375397513328
2,325
1300351
13
229681
10194
125154673
01000102
265
1212
98
54
10001215
00001
100
11
00000000
17261020145445
186
00000011
2665
160435150144113
1,093
01101306
1312171
16
00000101
1212314
14
00000000
1231980393123
216
04001005
4282014162412
118
00002103
49104
6679835856
495
11001003
12361542344622
207
00000224
921
915191424
111
00100034
Cons
umer
Loa
n Fr
aud
Cou
nter
f ei t
Cred
it /D
e bit
Card
Deb
i t C a
rd F
raud
2811579
10873
177211791
1220967
27
9175
1310275
86
00001001
11
107
11191867
01003206
State/Territory Violation
94
00000000
Palau1996199719981999200020012002TOTAL
00000000
Wire
Tra
nsf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
gB r
i ber
y /G
ratu
i ty
Ch e
ck F
raud
Che
ck K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it C a
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
00000101
00000000
00000000
00000000
00000000
00000000
00000011
00000101
00000000
00000000
00000000
00000000
00000000
00000000
00000000
Con
sum
er L
oan
Fra u
d
Coun
t erf e
i t C r
edit /
Deb
i t C
a rd
Deb
it Ca
rd F
raud
00000101
00000000
State/Territory Violation
95
34834550706872
422
574276
1344
Pennsylvania1996199719981999200020012002TOTALPuerto Rico1996199719981999200020012002TOTAL
102035478064
125381
2001517
16
Wir
e Tra
n sfe
r Fra
u d
Oth
er
B SA/
Stru
ctur
ing/
Mon
ey L
aun d
eri n
gB r
i ber
y/G
rat u
i t y
Chec
k F r
aud
Chec
k K
i t in g
C om
me r
c ial
Loa
n F r
aud
Com
pute
r Int
rusio
n
Co u
nter
fei t
C hec
k
Cou
nter
feit
Inst
rum
ent (
Ot h
er)
Cre
dit C
ard
Frau
d
Def
a lca
ti on/
Embe
zzl e
men
t
F al se
Sta
t em
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mo r
t ga g
e Loa
n Fr
a ud
Mys
teri o
us D
isap p
eara
n ce
459952975
1,7401,6051,9952,790
10,516
95475348234629983
1,0823,846
151024
1225
1020723
15
164496393475528632807
3,495
4212023
16166
122417
67124110122149206197975
1887
332258
137
4232724293442
183
3600614
20
00001
251440
00001236
25343653765852
334
84
132
259
1374
62236201192219230379
1,519
2364
1057
37
041
1458
2355
2000224
10
34496
131958
23010107
1172445947
10595
433
2151312723120
165
10241623433958
213
0364
39269
87
54142114128221227190
1,076
10131515271719
116
24593839647569
368
675
14331626
107
16594143538366
361
1315143
14142598
Cons
umer
Loa
n Fr
a ud
Cou
nter
f ei t
Cred
it /D
ebit
Car
d
Deb
it Ca
rd F
raud
98212258241261439595
2,104
9114423595167
264
10241717
93880
195
1432655
26
State/Territory Violation
96
Rhode Island1996199719981999200020012002TOTALSouth Carolina1996199719981999200020012002TOTAL
0241524
18
012
10231382631
240
Wire
Tra
n sf e
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mo n
ey L
aund
erin
gB r
iber
y/G
ratu
i t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r In t
rusi
on
Cou n
t erfe
i t C
hec k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cred
it Ca
rd F
raud
De f
alca
t i on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
70127136255281226480
1,575
139229260304300357531
2,120
00000011
01031005
2351485582
104121484
28755764
140141140645
614161219157
89
18333432575870
302
2322014
14
210
417
134
41
00001001
00000000
210159359
53
8161110141629
104
3221817202120
121
7213343515554
264
00001315
00011114
02002105
1211152
13
330
8100
2827
158354
6131418213514
121
1121716
19
0333298
28
4366
26201883
25612950365938
298
5987425
40
918
913132118
101
1144846
28
4231727162223
132
Con s
umer
Loa
n Fr
a ud
Coun
terf e
i t C
redi
t/Deb
i t Ca
rd
Deb
i t Ca
rd F
raud
10221920222525
143
2252516060
105145495
775196
1853
13371836183328
183
00010012
030448
2140
State/Territory Violation
97
South Dakota1996199719981999200020012002TOTALTennessee1996199719981999200020012002TOTAL
00000101
057
1439
156114335
Wire
Tra
nsf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
aund
eri n
gB r
i ber
y /G
ratu
i ty
Ch e
ck F
raud
Che
ck K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it C a
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
858817281
11788
505
148260305324771886821
3,515
00120104
1122465
21
51933
3013254
8851,329
6188
128160176212190
1,015
3117818264047
223
98145807496
151119763
36
126
134
1963
10292022293449
193
00000101
0000482
14
222465
1334
15273440435428
241
108
106
142665
3193851639669
339
321
864668
452658
020214
1019
3012180
15
2352723
24
258308292125
29109
1,2692,390
7161226307151
213
00320027
128
11697
44
5101018122144
120
5394
109115115128
83697
36
1499
142075
1422646354
10556
378
23
1416
27
1256
15394769568641
353
Con
sum
er L
oan
Fra u
d
Coun
t erf e
i t C r
edit /
Deb
i t C
a rd
Deb
it Ca
rd F
raud
41521252258
1,0971,242
4570
104107194195175890
6568
1112
856
27432446463443
263
1110346
16
2345788
37
State/Territory Violation
98
Texas1996199719981999200020012002TotalU.S. VirginIslands1996199719981999200020012002TOTAL
0365
34381298
00000000
345433489486590
1,0851,3324,760
0100054
10
21412972
218222261864
00000000
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA /
S tru
c tur
i ng/
Mon
e y L
aund
eri n
gBr
i ber
y/G
ratu
i t y
C hec
k Fra
ud
C hec
k Kit i
ng
C om
mer
cial
Loa
n Fr
a ud
C om
p ute
r Int
rusi o
n
C oun
t erf e
it C
h eck
C oun
terf e
i t In
st rum
e nt (
Oth
e r)
C red
i t C a
rd F
rau d
Def
alc a
ti on/
E mb e
zzl e
men
t
F alse
St a
t em
ent
Mi su
se o
f Pos
i t io n
or S
elf D
eal i n
gM
ort g
age L
oan
Frau
d
Mys
t erio
u s D
i sapp
eara
nce
1,8632,7243,7704,8406,3428,4978,863
36,899
0574
194549
129
223
11106
2256
00000000
426632675507980
1,4161,5486,184
10010338
115216249259314515587
2,255
00050106
31686874
10011298
551
00000101
00003
391860
00000000
4667
101276369332351
1,542
01001002
127128286315460667601
2,584
01100013
9361725252536
173
00001001
36136137171144223153
1,000
0003034
10
1324
927456430
212
00000000
168322323341382378347
2,261
1022320
10
87111112133146191172952
10001002
53103
89132161175215928
20003106
Cons
umer
Loa
n Fr
aud
C oun
t erf e
it C
red i
t /Deb
it C a
rd
Deb
i t C a
rd F
rau d
119127123121202147112951
00010001
2536304557
103124420
00100001
State/Territory Violation
99
Utah1996199719981999200020012002TOTALVermont1996199719981999200020012002TOTAL
02
6513333837
188
01010013
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA /
S tru
ctu r
i ng /
Mo n
ey L
aun d
eri n
gBr
iber
y/G
ratu
it y
Chec
k F r
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n F r
aud
Com
put e
r In t
rusi o
n
Coun
t erf e
it Ch
eck
Coun
t erfe
it In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
E mbe
zzl e
men
t
F al s
e St
a tem
ent
Misu
se o
f Pos
i t io n
or S
e lf D
eali n
gM
ortg
age
L oan
Fra
ud
Mys
t eri o
us D
i sap p
eara
nce
27152312435630619655
2,830
14261619302755
187
00110002
00000000
29786991
148546596
1,557
11191147
191586
163128235058
138344
9439
1174
47
152384
1437
0630021
12
00000011
00000101
122215111377
227377
1323111
12
3101225457051
216
0201529
19
01057
5961
133
01110014
12095
122
31
00000000
121475449666
1,2031,2951,2465,455
0576144
27
02310
344
11441
235
03012219
15505835393939
275
4945349
38
7172125836825
246
4524240
21
8181918233648
170
2752217
26
Con
sum
er L
oan
Frau
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
i t C a
rd F
rau d
22240368570
1,1471,4291,4795,255
43668
232272
13
101
1368
42
1165022
17
039268
2048
11011138
State/Territory Violation
100
Virginia1996199719981999200020012002TOTALWashington1996199719981999200020012002TOTAL
10275137639166
345
71916223852
137291
Wire
Tra
nsf e
r Fra
ud
Oth
er
BSA /
S tru
ctu r
i ng /
Mo n
ey L
aun d
eri n
gBr
iber
y/G
ratu
it y
Chec
k F r
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n F r
aud
Com
put e
r In t
rusi o
n
Coun
t erf e
it Ch
eck
Coun
t erfe
it In
st rum
ent (
Oth
er)
C red
i t C a
rd F
raud
Def
alca
t ion/
E mbe
zzl e
men
t
F al s
e St
a tem
ent
Misu
se o
f Pos
i t io n
or S
e lf D
eali n
gM
ortg
age
L oan
Fra
ud
Mys
t eri o
us D
i sap p
eara
nce
109325500490569973
1,0674,033
257636798
1,1941,6221,602
9537,062
1061424
18
0101236
13
76262204184323413412
1,874
182481565935845882541
4,431
38138106115139162118816
3511413112697
15884
745
1011111067
1166
3799
179
1367
0000073
10
00002226
1668353561
196196607
21484746235837
280
1355
12093
188137185791
63147316545363342277
2,053
159
22303352
152
14311
269
45
086277
1040
3130362
18
35208182172181511208
1,497
83326341737
155310
2378
433224
119
7627727326642
313
45124141124172148118872
5613411392
14913184
759
14615835408357
348
234541638186
104443
19494775
1027875
445
10202318294335
178
Con
sum
er L
oan
Frau
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
i t C a
rd F
rau d
53110116121182305430
1,317
499587
113150244345
1,083
28325273535846
342
109
1719161910
100
5111654104031
167
16
1056161522
126
State/Territory Violation
101
West Virginia1996199719981999200020012002TOTALWisconsin1996199719981999200020012002TOTAL
00
486488
300
977
210
11011141159
Wire
Tra
n sf e
r Fra
u d
Oth
er
BSA/
Stru
ctur
i ng/
Mon
ey L
a und
eri n
gB r
i ber
y /G
ratu
i ty
Chec
k Fr
aud
Chec
k K
i t in g
Com
mer
cial
Loa
n Fr
a ud
Com
pute
r Int
rusi o
n
Coun
t erf e
i t Ch
eck
Cou n
terfe
i t In
st rum
ent (
Oth
er)
Cred
it Ca
rd F
raud
Def
alca
t i on/
Embe
zzl e
men
t
Fal se
St a
tem
ent
Mis
use
of P
osi t i
on o
r Sel
f Dea
l i ng
Mor
tgag
e Lo
an F
rau d
Mys
teri o
u s D
i sapp
eara
nce
12252731375565
252
97203269301379431565
2,245
24000017
1110216
12
9162222251236
142
6295
103107182222212983
922201524
726
123
2049515557
10175
408
264552
1034
91623
9183013
118
00000123
00002417
883489
1050
46
1215143029
110
60749
101551
7173057787476
339
13010016
01004106
10100002
12348
102654
154
144665
54
07
2225164018
128
0222222
12
26488
101149
15242628331029
165
43708690
109116
75589
417
10318
37
816208
184524
139
210
143222
71
10395
12211726303442
182
Con
sum
er L
oan
Fra u
d
Coun
terf e
i t C r
edi t/
Deb
i t C a
rd
Deb
it Ca
rd F
raud
2337
525581242837
1,255
3755597793
189175689
35
149
156
1062
15301721504932
214
01201239
1235
11152865
State/Territory Violation
102
Wyoming1996199719981999200020012002TOTAL
00001078
Wire
Tra
n sf e
r Fra
ud
Oth
er
BSA /
Stru
ctu r
ing/
Mo n
ey L
aund
erin
gB r
iber
y/G
ratu
i t y
Che c
k F r
aud
Chec
k K
it ing
Com
mer
cial
Loa
n Fr
a ud
Com
put e
r In t
rusi
on
Cou n
t erfe
i t C
hec k
Cou
nter
f ei t
Inst
rum
ent (
Oth
er)
Cred
it Ca
rd F
raud
De f
alca
t i on/
E mb e
zzle
men
t
F al s
e S t
a tem
ent
Mi su
se o
f Po s
it ion
or S
elf D
eal in
gM
ortg
age
Loan
Fra
u d
Mys
t eri o
us D
i sap
pear
ance
5102512263745
160
00000000
36684
301976
12637
258
52
1242132
15
00000000
11101116
020037
1527
00200002
00000101
04411
601
71
01002003
6957
1114
658
1141906
22
1011472
16
Con s
umer
Loa
n Fr
a ud
Coun
terf e
i t C
redi
t/Deb
i t Ca
rd
Deb
i t Ca
rd F
raud
25647
302074
0100369
19
00210126
State/Territory Violation