By Cody Roberts, CRCM
What are the SAR Stats?
The Financial Crimes Enforcement Network (FinCEN) is a bureau of the U.S. Department of the Treasury that is designated to safeguard the financial system from illicit use, combat money laundering and promote national security through the collection, analysis, and dissemination of financial intelligence and strategic use of financial authorities. In particular, FinCEN receives and maintains financial transaction data, analyzes and disseminates that data for law enforcement purposes, and builds global cooperation with counterpart organizations in other countries and with international bodies.
One type of FinCEN’s periodic data analysis is published as SAR Stats; the most recent issue was released this month. This document, which is essentially an Excel spreadsheet with multiple tabs, shows Suspicious Activity Report (SAR) data for 2012-2016 arranged by:
- Year and Month
- States and Territories
- Type of Suspicious Activity
- Primary Federal Regulator
- Affiliation or Relationship
- Product Type(s) Involved in Suspicious Activity
- Instrument Type(s)/Payment Mechanism(s) Involved in Suspicious Activity
The authority of the Secretary of the Treasury to administer the Bank Secrecy Act is delegated to FinCEN. The Secretary was also granted authority in 1992 to require financial institutions to report suspicious transactions. These transactions are reported to the government via a SAR, a document that contains dozens of fields of information. As of 2013, SARs are reported exclusively electronically.
7 Interesting Items from SAR Stats – Issue 3 – Depository Institutions
A review of all nine exhibits (tabs) of SAR Stats is fascinating. A few of the more interesting items I found follow.
- The trend is that more SARs are being filed every year. Almost 960,000 were filed in 2016 alone!
- When looking at the SARs by state, the top five seem to make sense since they are states with large populations (California, New York, Ohio, Texas and Florida), but sixth is Delaware. Perhaps since Delaware is a state of choice for incorporating?
- The number one type of suspicious activity reported by depository institutions is “multiple transactions below CTR threshold.” It seems structuring is still a perennial concern to bankers.
- In the suspicious activity category of fraud, the suspicious activity type “ACH” has increased 178% in the past four years.
- Out of 13 affiliations or relationships, the one with the sixth most SARs filed in 2016 was employees of the institution, handily beating out officers, directors, owners and even attorneys.
- The product type most involved in suspicious activity was debit card—closely followed by credit card.
- The top instrument type/payment mechanism involved in suspicious activity was (not surprisingly) currency. However, the second type was funds transfers.
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