By, Cody Roberts
As compliance officers – especially BSA compliance officers – we tend to look at ourselves as over-tasked and under-appreciated. No bank employee likes to be told to fill out a form, take a BSA training test or answer questions about transactions. Thanks are rare from board members who get reports of SARs and CTRs to let them know how their institution is combatting allegations of money laundering, illegal narcotics sales proceeds, terrorism, tax evasion or other illegal activities that may be perpetrated through the bank. However, occasionally the compliance department can get some satisfaction that they made a difference.
Recently, former Speaker of the House Dennis Hastert admitted to being a serial molester and paying hush money to one of his victims. The judge in the case noted, “What rational person takes $1.7 million in cash out of a bank over 4 1/2 years in a series of $50,000 and $9,000 withdrawals?…Add to it that the person who is doing it is the former speaker of the House, and you have a set of circumstances that cry out for investigation.” Ultimately, Hastert was indicted on structuring charges.
The interesting point in this case was how Hastert’s activities were found out. Evidently, it was an alert compliance officer at a bank who noticed the nature of the transactions that led to the investigation. Although I did not see any mention of it, it is likely a SAR was (or a number of SARs were) filed showing unusual and large cash transactions.
Sometimes we compliance folk do make a difference.
