The FinCEN Files data breach has highlighted several of DSA’s prior blog posts on Suspicious Activity Reports (SARs), SAR confidentiality, and IRS AML oversight.
DSA’s 2018 SAR analysis was cited in an NBC article “Secret documents reveal potential dark side of pre-paid debit cards” by Gretchen Morgenson and Kit Ramgopal. NBC links to DSA’s 2018 SAR analysis in a discussion on the number SARs filed. Each year, DSA analyzes SAR filings by category, financial institution (FI) type, geographic area to uncover trends & insights.
IRS AML Oversight
Additionally, the NBC article discusses IRS AML oversight of MSBs. The IRS is the primary BSA regulator for the largest number of FIs, its FIs file the most SARs and the IRS conducts the most BSA exams by count. Businesses that are regulated by the IRS include casinos, Money Services Businesses, Dealers of Precious Metals, Virtual Currency Exchanges, Providers of Prepaid Access Cards and Insurance companies.
DSA’s analysis of IRS money laundering enforcement actions compared against other BSA regulators found:
The IRS has the lowest rate of formal enforcement actions despite finding the greatest number of violations per exam.
IRS FIs have a low likelihood of being subject to a BSA exam given the huge number of FIs in the pool, and the chance of a BSA formal enforcement action is minuscule.
