The FinCEN files are a “leak” based on information obtained by Buzzfeed News. They were shared with the International Consortium of Investigative Journalists  (ICIJ) and contain 2,100 Suspicious Activity Reports (SARs) totaling $2 trillion filed with the U.S. Department of Treasury’s Financial Crimes Enforcement Network (FinCen) between 1999 and 2017 (a 17-year time span).  The FinCEN files demonstrate that despite the filing of a SAR, organizations continued to do business with the entities and the individuals highlighted in the SAR. Furthermore, the FinCEN files pose the questions of why did these organizations continued to do business as usual with these entities and individuals, and if the BSA/AML obligations just end with the filing of a SAR?

Who Must File the SAR?

  • Bank and Financial Holding Companies
  • Casinos and Card Clubs
  • Money Services Businesses
  • Brokers or Dealers in Securities
  • Mutual Funds
  • Insurance Companies
  • Futures Commission Merchants
  • Introducing Brokers in Commodities
  • Residential Mortgage Lenders and Originators