Several key threats including Drug Trafficking, Organized Crime and Tax Evasion do not have SAR category checkboxes. SAR data is only "useful" to government authorities inasmuch as it is discoverable. Structured data is more easily searchable and will lead to improved AML effectiveness.
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The overwhelming majority of laundered funds originate from income tax evasion, yet there is no corresponding SAR category.
DSA's SAR analysis was cited by NBC in "Secret documents reveal potential dark side of pre-paid debit cards."
Broker-dealers look to enforcement actions to understand Finra's AML priorities. BDs may end up scouring their customer records to see if they have similar documentary issues … and that could draw funds and attention away from priorities identified in the National Strategy for Combatting Terrorist and Other Illicit Financing.
Alison Jimenez, president of Dynamic Securities Analytics, authored “Healthcare Fraud During a Pandemic: Fast Facts […]
There is a complete disjoint between what financial institutions are asked to report, what they do report, and national illicit finance priorities.
Alison Jimenez, president of Dynamic Securities Analytics, authored “What Financial Institutions Need to Know about […]
DSA analyzed SAR data and BSA regulator enforcement data to compare the level of regulator scrutiny.