Financial institutions can improve the value of their suspicious activity reports for law enforcement by taking steps such as providing citations and identifying known ties to foreign countries, Financial Crimes Enforcement Network Director Andrea Gacki said Monday. Speaking at an anti-money laundering conference in New York City, Gacki said her agency received nearly 119,000 SARs between April 1, 2022, and March 31 of this year, for an average of 5,000 a month. Given the importance of SARs to law enforcement, she shared three best practices for increasing their utility for FinCEN.
First, at the beginning of each SAR, include a “bottom-line, upfront” paragraph that identifies and explains why the reported activity is suspicious, Gacki said. Second, include a citation or clear explanation of any external information that triggered the determination that the activity was suspicious, such as news reports. Third, identify any links to foreign countries, including IP addresses. Such links provide FinCEN the opportunity to collaborate with its counterparts in other countries, she said.
Gacki also discussed FinCEN’s collection of beneficial ownership information, as required by the Corporate Transparency Act. She said the agency has received more than 1.7 million reports since the reporting requirement went into effect on Jan. 1. She also noted that the agency is continuing its phased approach to providing BOI access, with financial institutions scheduled to receive access in spring 2025.
