What does Bribery Look Like?

Dynamic Securities Analytics, Inc. (“DSA”) analyzed Suspicious Activity Reports (SARs) filed with FinCEN from March 2012 through March 2015 that identified “Bribery/Gratuity” as the activity at issue. The analysis was undertaken to understand the characteristics of customer activity identified as potential bribery from a financial institution’s viewpoint.


Key Takeaways:


  • 1,780 SARs were filed that identified “Bribery/Gratuity” with a customer as the subject
  • 80% of the SARs were filed by Depository Institutions and 9% by MSBs
  • Debit cards were identified as the product type in 68% of SARs that included a product type
  • Personal/business check was the #1 financial instrument identified, closely followed by U.S. Currency and then by Funds Transfer. These instruments were identified in 34.1%, 33.8% and 19% of SARs respectively.
  • Each SAR was connected with 1.6 types of financial instruments (ex. cashier’s checks, US currency, business check).


FIFA Alleged Bribery Scheme

The FIFA indictment included a variety of alleged bribery scheme payment methods that parallel those reported in bribery SARs. For instance:

“Jack Warner sent an email to First Citizens Bank, requesting the bank transfer $60,000 from the LOC Germany 2006 Limited account to his ‘personal checking account’.”

“Inside the room, CFU staff handed each official an envelope bearing the name of the member association that he represented. Inside each envelope was $40,000 in United States currency.”

“On or about November 21, 2012, two wire transfers of $750,000 and $250,000 were sent from Front Company A’s account at HSBC bank in Hong Kong to a correspondent account at Standard Chartered Bank in New York.”


The US attorney’s office is reviewing the actions of the banks that processed transactions mentioned in the FIFA indictment.


Part of our investigation will look at the conduct of the financial institutions to see whether they were cognizant of the fact they were helping launder these bribe payments,” Kelly T. Currie, acting U.S. attorney for the Eastern District of New York.



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