Leak reveals $2T of possibly corrupt US financial activity

https://www.occ.treas.gov/topics/supervision-and-examination...

Keep records of cash purchases of negotiable instruments, File reports of cash transactions exceeding $10,000 (daily aggregate amount), and Report suspicious activity that might signal criminal activity (e.g., money laundering, tax evasion)

If you do more than $10,000 in cash business/transactions, the bank will (must) file a report -- if you're deposit $8000 one day and $4000 the next day, the bank might be forced to consider it a single transaction for $12,000 -- and file a SAR.

There's fantastic reasons to keep this confidential -- Given that requirements to file are so broad, almost all of these are going to be normal business activity.

I think it's important to get the right mindset on what these are before we cry foul.

All banks will report 'large' transactions to their country's Financial Intelligence bureau. In the US, that's FINCEN. In Canada, that's FINTRAC, where I interned way back in 2006. Here, that means for all transactions over $10,000 CAD (or if the sum of transactions from an account within 24 hours exceeds $10,000), a report is filed, and FINTRAC keeps the report for 5 years while they look for signs of money laundering or terrorist financing. They data mine this to find patterns that indicate criminal activity. In 2006, while I was an intern, the Montreal mafia was brought down this way.

Suspicious Activity Reports, SARs are just what they sound like- the banker says 'something smells funny about this'. They want to let someone know about it. For example, let's say there's a particular person who moves $9,999 every day from his account to another one. That's under the $10,000 reporting limit but the bank can say "That's a bit weird, let's report it with an SAR". They can provide more details of why they're concerned.

The banks aren't the police. They don't know a crime has taken place. That person moving $9,999 every day could be doing something not criminal at all. And it's not the banks place to stop them- because that is just ripe for abuse. "Hey, I think all people of are suspicious, so anytime they move $1000 or more, I file an SAR and close their accounts". Or "Hey, that guy is part of , so I flag all his transactions with SARs".

In this case, there are SARs leaked related to some large transactions involving suspicious circumstances. That doesn't mean there's a crime! But it does mean that someone raised an eyebrow and flagged something so that it could be followed up on by the right government authorities.

It's up to the US FINCEN to decide if a crime took place and to handle it accordingly. You decide if you trust them or not, but that is their role in this.

(Do I think Paul Manafort is innocent? That is a whole different question.)

2000+ reports from between 1999 to 2017 amounting to a total of $2tn. Of those reports they only name-check Manafort, a Russian oligarch, and HSBC. How many people are feeling outrage because of the perceived connection between the current administration and corruption when these reports also cover years from the previous 3 administrations? How many characters connected to powerful Democrats could be found among these 2000 reports?

What if someone at the IRS leaked their flagged accounts as "possible tax fraud" or if Google leaked suspicious traffic logs as "possible cyber terrorism"? How much information could the general public be expected to glean about actual bad actors based on similar reporting? How many people here actually understand what an SAR contains and why it is created? Can anyone cite me what % of SARs turn out to be indicators of actual crimes?

I don't doubt that many of the people in these reports are guilty of crimes, but corruption investigations also take a long time and the more recent reports may very well be relevant to ongoing investigations and having them made public could spook suspects before authorities have gathered enough evidence to bring a charge.

That is all, carry on.